Megandps

We have a multiple employer plan with two companies, Company A and Company B. Company B is a participating employer in the Plan sponsored by Company A and the document says ADP/ACP testing is using prior year method. Company B came into existence in 2022, with only one employee who was classified as an HCE. In 2023, Company now has 2 employees, the one HCE and now one NHCE who transferred over from Company A and was previously eligible under Company A. The document counts past service between the two Companies. What is the prior year deferral percentage for the NHCE when testing for 2023 in Company B? 0% or 3% since it is the first year Company B has NHCE employees? Can Company B elect to change to current year testing or must both Company A and B move to current year testing?

Any other Relius users have this issue? I'm wondering if I have a setting in Plan Specs not marked correctly. When I run the 410(b) Coverage test, Relius is including Terminated Participants with <500 hours as eligible for the test. However I know this group of participants is allowed to be excluded from the test. Am I missing something?

Our client is wanting to change their eligibility requirements to Age 21, 12 months of service and 500 hours, with plan entry being immediate. Basically if the employee is at least 21 and has completed 500 hours within their first year of employment, they would enter the plan as of their 1 year anniversary date. Where we are getting stuck is what if the employee does NOT meet the 500 hours within the anniversary year? We would be switching to evaulating the 12 month period then on a plan year basis. If the employee then completed 500 hours between the plan year of 1/1 and 12/31, does the entry date become 12/31 of the plan year the 500 hours was completed, or is it 1/1 of the following plan year?

I've been trying to research this issue but so far have fallen short. The plan's eligibility for employee deferrals is age 21. But eligibility for Safe harbor NE and Profit Sharing is age 21 with 1 year of service. We are assuming because eligibilty for the Safe Harbor is more restrictive than that of employee deferrals, we do not get the "free pass" on ADP testing. The question becomes, who then do we include in the ADP test? What we think is the employees that need to be included would be those who have met eligibility for employee deferrals, but NOT eligibility for Safe Harbor contributions. However, we are having difficulting finding that anywhere. Thoughts?

The loan policy states a loan may only be taken for a safe harbor hardship reason. What if the documentation of the financial need ($900 medical bill) is less than the loan minimum ($1,000)?

We are looking for some clarification. The way we are reading the guidelines, the effective date of the restatement period is the later of January 1, 2010 or the plan effective date. Example: 403b plan that was effective 10/1/1991 and restated 10/1/2012. Are we now restating effective 1/1/2010 or 10/1/2012? Our innital reaction was to use 1/1/2010, but we are second guessing that because of the later 10/1/2012 restatement.

It is outside of the retirement plan. I was along the same thinking that if permitted, it may be more hassle to design the form than it's really worth. It is a large plan, and while the one beneficiary form would cut down on the forms the participant would need to fill out, we are hesitant because it may not be as clean as keeping the forms separate.

If the beneficiary form clearly states the name of the retirement plan and the name of the insurance policy, can the one form be used? A client of ours was trying to cut down on making employees fill out two different beneficiary forms when the employee wants the same beneficiary for both.