SSRRS

Thank you. In addition to the TPA not being required to provide the information, is the TPA legally allowed to provide any information? Thank you.

JackS, thank you very much!

Hi, If a plan participant (active, or terminated employee) requests information regarding a qualified DC Plan that a company sponsors.1 Who is required to provide the information, the TPA or the plan sponsor/administrator (ie the client)? 2. Is the TPA prohibited from providing any information since the TPA is not the sponsor/administrator? Thank you.

Thank you . Your vast knowledge and help is much appreciated. Yes, the auditor is questioning why the contract value was used. In.defense, asset smoothing is allowed even though it is not the actual current value. In addition, if the plan is overfunded and faces a possible reversion and excise tax, using the larger contract value actually is a more accurate indication of the potential reversion that the company might face down.the line.

Hi, A DB plan is invested in numerous annuities. A FASB report was prepared and the fair value of the plan assets used was based on the gross contract value, as opposed to the contract value less the withdrawal charge (surrender value). 1.Is this ok or should the value be the surrender value? 2. If the plan is overfunded either way is this an immaterial issue? Thank you.

Thank you Effen for your clear and detailed insights. This particular case invloves an NHCE; however, your point about non-discrimination is good to be aware of for other cases.

An employee was excluded from a DB Plan for the past three years (backed by plan document). The plan met 410(b) and 401(a) (26) without having to include this employee. For the current year (and forward) the employee will be included. The benefit formula is based on service. The employee was not excluded based on job classification or union status etc, rather he was excluded by name. If the document states that benefits will not accrue for years that an employee was part of an ineligible class, will the employee only accrue a benefit for the current year and not for the prior years of service (or now that the employee is a participant he will accrue benefits for the prior years as well)? Thank you for any insights on this.

Company A was sold in an asset sale. Thank you Lou S.

jpod, thank you very much. Yes, this is fact critical., however, the fact that you have pointed out that this is a controlled group brings clarity.

Hi, I would greatly appreciate insight on this matter. Client had a company "A" (since 09) and a DB PLAN for company A since 2012. In March 2019 he sold "A" --however, corporation is still in existence and its only asset is aprox 10,000 in cash. In April 2019 he set up a new corp "B" (set up a corp and purchased the assets of a business). Company B has new employees and does not do the same service as '"A" corp did. 1. Is he allowed to continue the DB Plan of 'A" for company "B'? (so that he has prior service and benifits from "A" and salary average from "A")? 2. If yes, is the owner the only employee eligible to participate in the plan for 2019 (as he has a year of service from the prior company and is the ONLY employee that will have 1,000 hours for 2019). Thank you very much for any insight on this matter,

Thank you very much Lou and CuseFan for your insight and help.

Thank you very much, Lou. He became non union on 8/31/17, If the entry dates are 1/1 and 7/1 he would not enter the plan until 1/1/2018. Correct?

Hi, A DB Plan excludes union employees (covered by collective bargaining agreement). An employee was hired by the company on 3/11/15 as a Union employee and was covered under their pension plan until he moved to a Non union managerial position on 8/31/17. If the plan's eligibility requirements is 12 months, would he not enter the plan until 12 months following 8/31/17 (1/1/19 due to entry date) or would he be eligible immediately on 8/31/17 due to the service for the company since 3/11/15 (ie using the service while a union employee). Thank you.

Thank you Mike.

If husband at age 70.5 elected a 100% J&S annuity and passed away can the surviving spouse now take a lump sum that is equivalent to her receiving a monthly annuity (ie lump sum of the 7,500 monthly that she is supposed to receive)Thank you very much.

Thank you CuseFan for this important information.

Manatee, thank you. Much appreciated.

CuseFan, thank you.

A corp. made numerous contributions to their DB Plan during the months of January thru September 2018. These contributions can either be used for the 2017 year-(of course must be within the min/max range) (as made by extended due date of 2017 return -sept. 15, 2018) or for the 2018 year. Question: Can you use contributions made in January, February, and June 2018 for the 2017 tax year and then use contributions that were made in March, April and May 2018 FOR THE 2018 tax year, or must you go in order (ie contributions made from Jan thru April 2018 for the 2017 tax year and then contr. made from May 2018 thru Sep 2018 for the 2018 tax year). Thank you.

This is from a while ago, but if possible, I would really appreciate more clarity on this. 1. If we are doing EOY Vals, would the accrual of .5 % for year of participation that would be given to a new participant (to cover 401(a0(26)) be shown in the FT only (as an A/B that was there as of beg of the yr. and no increase) or that there was zero A/B at the BOY and the .5% accrual as an increase (and shown in the TNC -and there would be no FT for this new partc.) 2. If it is shown as a Benefit increase and a TNC --if the plan is hard frozen, how is this done, is it a special corrective method that is allowed even though the plan is frozen? Or is the idea that that the plan formula is being amended to a .lower formula of .5% per yr of participation -with wear away- and therefore the net result is that only the new participant is getting an accrual of .5% for the current year since the benefit that the others have accrued until now is in excess of this new formula of .5% pr year of participation? Thank you very much.

It would be greatly appreciated if someone could shed light regarding the above. Thank you

Thank you Unfunded and CuseFan for your help. The plan is not underfunded and therefore we will add a new participant (to cover 40%) and give a benefit of .005 for the year of participation. Question: Since the plan is hard frozen should this benefit that is being given to the new partic[pant be shown as a benefit that was there already as of the beg. of the year (funding target-sort of a correction to pass 401(a)(26)) and not as an increase (and no TNC), as since the plan is hard frozen and there are no accruals to the rest of the participants, it seems strange to have this new participant getting an increase ? Thank you

Thank you.

Someone mentioned to me that a DB Plan that they administered was taken over by a new firm. The new firm is asking the prior administrator/actuary to back up (ie show the calculations for each participant) the accrued benefits for all participants that are in the most current valuation (7 participants). Is this something hat is required of the prior Actuary ? Thank you.

A frozen DB Plan (hard freeze) that is not covering enough active employees to pass 401(a)(26) can add a new participant (if all that is needed is one more participant to satisfy 40%) and give a .5% accrual for the current year as is suggested above. I have seen this solution being advised on numerous occasions. Can someone please help me understand this method, as if the plan is frozen how is this (minimal) accrual being given to a new participant (and all current participants are not given an accrual for the current year)? Is it allowed as a special corrective measure? If yes, is an amendment required stating that " an accrual of .5 will be given to a new participant to comply with 401(a)26)"? Thank you in advance for shedding light on this topic.