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Jeff Hartmann

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  1. Like
    Jeff Hartmann got a reaction from Calavera in Contribution Eligibility - Profit Sharing + Cash Balance Plans   
    Generally, when a Cash Balance plan is adopted,  the Profit Sharing plan  should provide (or amended to provide) that there is no End of Year employment requirement  .....  because it usually better (cheaper) to provide staff benefits in the PS plan.
     
    ....  Jeff
  2. Like
    Jeff Hartmann got a reaction from Paul I in RMD Start date - checking   
    If participant born 4/11/1952 is terminated or was a 5%-owner,  his  Required Beginning Date is  April 1, 2026    (not 12/31/2025).
     
    ....  Jeff
  3. Like
    Jeff Hartmann got a reaction from C. B. Zeller in RMD Start date - checking   
    If participant born 4/11/1952 is terminated or was a 5%-owner,  his  Required Beginning Date is  April 1, 2026    (not 12/31/2025).
     
    ....  Jeff
  4. Like
    Jeff Hartmann got a reaction from C. B. Zeller in so confused about segment rates   
    Your segment rates for 430 should be  5.03/5.27/5.59, because the first two 404 rates fall within the 95%-105% corridor of the 25-year average segment rates.
     
     
    .....  Jeff
  5. Like
    Jeff Hartmann got a reaction from Lou S. in 2023 RMD expectancy tables   
    Actually,   SECURE (1.0) updated the minimum age to 72, but did not contain any language about updating the life expectancy tables.    The tables updates were done by IRS regulations  proposed in November 2020  (and finalized in late February 2022).
    Again,  SECURE 2.0 just updates the minimum age to 73, but does not update the life expectancy tables.    My guess is that IRS is not planning another update immediately to the life expectancy tables,   but if they are planning to update the tables it would be announced well ahead of time and not take effect before 2024 at the earliest.
     
    .....  Jeff
  6. Like
    Jeff Hartmann got a reaction from Lou S. in DB RMD related   
    Is this for a DB or DC plan?   The rules differ.      I will state my answers for a DB plan ......
    1.   For an annual payment by  4/1/2023,  RMD payment should be the annual RMD,  $24,000.     April 1 is a BEGINNING date, for monthly payments,  but for an Annual RMD, you should pay the entire Accrued Benefit x12  as of  12/31/2022.
    2.   At least  $24,000, plus an interest adjustment  (actuarial increase) for delayed payment that was due  4/1/2023.   There is also potential 50% Excise Tax for missing 4/1/2023 deadline.   What/when is the NEXT RMD payment going to be?
    3.  $36,000 should be received in  2024.  I think this should be paid around  4/1/2024  (or 1st anniversary of 2023 payment, if earlier than 4/1/2023).
     
    ....  Jeff
     
  7. Like
    Jeff Hartmann got a reaction from Jakyasar in DB RMD related   
    Is this for a DB or DC plan?   The rules differ.      I will state my answers for a DB plan ......
    1.   For an annual payment by  4/1/2023,  RMD payment should be the annual RMD,  $24,000.     April 1 is a BEGINNING date, for monthly payments,  but for an Annual RMD, you should pay the entire Accrued Benefit x12  as of  12/31/2022.
    2.   At least  $24,000, plus an interest adjustment  (actuarial increase) for delayed payment that was due  4/1/2023.   There is also potential 50% Excise Tax for missing 4/1/2023 deadline.   What/when is the NEXT RMD payment going to be?
    3.  $36,000 should be received in  2024.  I think this should be paid around  4/1/2024  (or 1st anniversary of 2023 payment, if earlier than 4/1/2023).
     
    ....  Jeff
     
  8. Like
    Jeff Hartmann got a reaction from C. B. Zeller in DB RMD related   
    It's unclear to me what you mean by a "Lump Sum withdrawal" ?
    Do you mean a "lump sum" of 12 monthly payments ($2,000 each), or a "Total Distribution" of his entire Accrued Benefit?   If he is NOT terminated, does the plan permit In-Service Withdrawals of his entire Accrued Benefit?
    If this is a total distribution, and the plan allows In-Service Withdrawals,  the total distribution might be worth around  $264,000    (2,000 x 12 x approx 11 [APR] ).
    If by "lump sum withdrawal", you just mean 1 annual payment  (vs. 12 monthly payments of $2,000) you should be able to pay a $24,000 annual RMD payment before 4/1/2023, if plan document allows annual payments of the RMD's.
     
    P.S.  you didn't say whether the  $1,000 / $2,000 AB's  were monthly benefits or annual benefits, but the discussion implied this was a Monthly Accrued Benefit.
     
    ....  Jeff
  9. Like
    Jeff Hartmann got a reaction from Luke Bailey in Deduction question when plan year different than tax year   
    <<if a contribution is made by the due date of the 9/30/2021 Form 5500 - 7/15/2022 - and we therefore show this as applying to the PYE 9/30/2021,>>
     
    I don't think a contribution made in July 2022 can be reported anywhere on the Form 5500 (or Schedule SB) for the plan year ending 9/30/2021.   Contribution must be made by June 15, 2022 to be included in the financial reporting of the Form 5500.
     
    ....  Jeff
  10. Like
    Jeff Hartmann got a reaction from acm_acm in Do you in an SPD or SMM describe a provision that expired?   
    Personally, I think the biggest issue in your example  (CRD available only for several months during 2020) is the failure to TIMELY communicate to the participants their right to a special distribution before the expiration of such rights.
    i.e.  what is the point of adopting such (an optional) provision if they are going to wait until 7 months after the expiration of the provision?
    Notwithstanding the statutory deadline of July 31, 2021, an SMM explaining this provision should have been provided immediately after adoption of the amendment.
    ......  Jeff
  11. Like
    Jeff Hartmann got a reaction from Luke Bailey in Do you in an SPD or SMM describe a provision that expired?   
    Personally, I think the biggest issue in your example  (CRD available only for several months during 2020) is the failure to TIMELY communicate to the participants their right to a special distribution before the expiration of such rights.
    i.e.  what is the point of adopting such (an optional) provision if they are going to wait until 7 months after the expiration of the provision?
    Notwithstanding the statutory deadline of July 31, 2021, an SMM explaining this provision should have been provided immediately after adoption of the amendment.
    ......  Jeff
  12. Like
    Jeff Hartmann got a reaction from Bill Presson in Projected limits?   
    Cost of living increase this year is only around  1.18%, so most plan limits will not increase in 2021.
    The only expected increases for 2021 are:
    DC limit   $58,000
    Compensation limit   $290,000
     
    The September 2020 CPI report will be issued by DOL early  tomorrow morning, which will "finalize" my projections, but I don't expect a large enough change (up or down) in the CPI-U index to affect any other limit.
    .....   Jeff
  13. Like
    Jeff Hartmann got a reaction from Luke Bailey in PBGC missed contribution reporting   
    This is the explanation that we are providing on Form 5500-SF, line 11b:
    [x] No.  Other.     PBGC Notification is not required yet because the Funding Deadline is January 1, 2021.”
     
    ....  Jeff
  14. Like
    Jeff Hartmann got a reaction from ugueth in CARES Act IRS Notice 2020-61 for DBs: PSA   
    Without (yet) addressing EVERYTHING in your post, I want to say that the 2020 Effective Interest Rate only applies to contributions deposited between  September 16 and December 31, 2020.  Furthermore, this 2020 rate only applies to discounting the contribution amount back to  September 15, 2020,  with the remaining discounting (back to 1/1/2019) using the 2019 Effective Interest Rate.
    Contributions deposited on or before (the original due date) September 15, 2020 are discounted using the 2019 Effective Interest Rate.
    P.S.  I was disappointed to see that the IRS rules did not "technically correct" the error in the law.   That is,  ALL discounting should be at the 2019 rate, to be consistent with all prior rules under PPA.
    ...  Jeff
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