Rayofsunshine

We have always been a Volume Submitter and now a pre-approved individually designed plan office. Sorry if they are not the exact terms. In other words no prototypes and have never had opinion letters in our name. Hope that makes sense. I feel like we're not the norm, and most providers use non standardized prototypes but maybe I'm wrong. If you do use IDP documents how difficult is it to amend your plan (discretionary amendments)? We use relius IDP documents and up until PPA(i believe) we were able to use their short amendment module to amend the VS documents. It was super easy it created the language for the amendment and SMM etc. However, since then it's become a very manual process. The module just provides a blank Amendment, SMM etc. and i have to add the modified language. If you use preapproved IDP do you agree or if you use another doc provider, are you able to amend easier.... maybe it just me, I'll should say I'm not an attorney

is anyone having issues with logging in today. We've tried resetting the password etc. and still no success. No one at my firm is able to log in. All are receiving an error for an invalid log in attempt even after resetting the password.

This is a weird ...A client would like to exclude bonuses from deferrals but not match. In short, they are finding it a pain to set up the deferral's deductions via payroll, so they don't' want to allow participants to be able to defer from their bonus but don't mind matching on bonus compensation. Is this permissible. The match formula is 33% up to 6% funded annually, I believe for anyone that defers over 6% it doesn't matter that they can't defer on bonus they will get match on the total gross. However, if they defer less than 6% then there's nothing to match on. I feel like this set up may be discriminatory. Do you see anything wrong with this set up? Overthinker here so sorry if this is a stupid question. Here are the match examples: 10% deferrals (more than 6% example) Base Compensation $125,000 Bonus Compensation $10,000 Gross $135,000 - participant defers $12,500 which is 10% of their base salary, they cannot defer on the $10k bonus. Calculating the match in this example if match includes bonus would mean the match is $2673. ($12,500/$135,000=9.26% deferral % they are deferring more than 6% so 135k*.6%*33% =2673). It doesn't matter if they had deferred the 10% on the bonus the match would still be the same. 5% of deferrals (less than 6% example) Base Compensation $125,000 Bonus Compensation $10,000 Gross $135,000 - participant defers $6,250 which is 5% of their base salary, again they cannot defer on the $10k bonus. Calculating the match in this example if match includes bonus would mean the match is $2,062.50 ($6250/$135,000=4.63% deferral % they are deferring less than 6% so 135k*.4.36%*33% =2062.50) However, in above example let's assume they were able to defer on bonus, the match would be $2227.50 (6750/135000=5%) 135k*5%*.33=2227.50. Again we/I may be overthinking this but if they defer less than 6% and cannot defer on bonus, they truly get less of a match than if they deferred more than 6% they end up benefiting even though they can't defer from bonus.

not sure if we are the only ones that do this, but if a plan funds their safe harbor match or even a discretionary match on a payroll basis what's the easiest way to check it at the end of the year :). We have relius calculate it for some of our plans each payroll (match report sent etc.). We don't need to check those...however there are some plans where the HR or payroll company calculates, and we try to double check at the end of the year. Right now, we check each person, every payroll which is time consuming especially for large plans. Wondering if there's an easier way to do it on relius?

thank you both this is the definition for a Year of Service in the plan document. @Belgarath I believe you are correct based on the definition below. I'll wait to hear back from FIS as well though. thanks! 1.113 "Year of Service" means the computation period of twelve consecutive months, herein set forth, and during which an Employee has at least 1,000 Hours of Service. However, the Employer may amend the Plan to provide a lesser number of Hours of Service in a Plan amendment for eligibility purposes, vesting purposes, or accrual purposes without adversely affecting the Plan's reliance on the IRS Opinion Letter. For purposes of eligibility for participation, the initial computation period shall begin with the date on which the Employee first performs an Hour of Service. The participation computation period shall shift to the Plan Year which includes the anniversary of the date on which the Employee first performed an Hour of Service. If there is a shift to the Plan Year, then an Employee who is credited with the required Hours of Service in both the initial computation period and the Plan Year which includes the anniversary of the date on which the Employee first performed an Hour of Service, shall be credited with two Years of Service for purposes of eligibility to participate. A Year of Service for eligibility purposes is not credited until the end of a participation computation period. For vesting purposes, the computation periods shall be the Plan Year. The computation period shall be the Plan Year if not otherwise set forth herein. In the event the method of crediting service is amended from the elapsed‑time method to the hour‑of‑service method, an Employee will receive credit for Years of Service equal to: (a) The number of Years of Service equal to the number of One‑Year Periods of Service credited to the Employee as of the date of the amendment; and (b) In the computation period which includes the date of the amendment, a number of Hours of Service (using the Hours of Service equivalency method elected in the Plan) to any fractional part of a year credited to the Employee under this Section as of the date of the amendment.

We use FIS IDP pre-approved plan documents and have submitted the question to them. However, I wanted to post on here as well to see if anyone may know. The plan document uses failsafe YOS language when we enter eligibility that's less than one year and includes hours. See language below for the plan in question: (a) Eligibility. Any Eligible Employee who has completed 167 Hours of Service within 2 consecutive months from the initial date of employment and has attained age 21 shall be eligible to participate hereunder as of the date such Employee has satisfied such requirements. Notwithstanding the foregoing, any Employee who has completed a One-Year of Service shall be deemed to have met the service requirement. Plan Entry Dates are 1st of the month. Our understanding of the eligibility above is that if an employee does not complete 167 hours in 2 their first two consecutive months of employment. They have to complete 1000 hours in 12 months. For example, if an employee was hired January 23, 2023, on March 23rd they completed 2 months of service and on April 1st they would enter the plan as long as they completed 167 hours within the 2 months. However, what if the person only complete 80 hours in the 2 consecutive months. They are not eligible to enter the plan on April 1st, correct? They will now need to complete a year of service which is 1000 hour within 12 months? Let's assume they completed 1000 hours by September 15, 2023. Do you agree that they would be eligible to enter the plan on that date? Some of the confusion here that a few of us believe that the year of service means that they have to complete 12 months of service (January 23, 2023, to January 23, 2024, and the 1000 hours) However, I disagree i believe a YOS only means 1000 hours in this case.

Thanks Lou for bringing that up, the safe harbor match notice requirement didn't cross my mind for the employees of company B. Yes we'll be sure to document everything if we go this route. Ah ok i didn't think we could merge in 2024, thanks!

We are in a bit of a pickle :). We are the TPAs for Company A. Company A is a safe harbor match plan (calendar year). Company A purchased Company B back in May of 2022 and never told us about it (of course). Company B has their own plan (non-safe harbor), they DID tell their service provider about the acquisition back in 2022. The service provider said NO PROBLEM you have 2 years due to the transition period thinking they had until May of 2024. Company A finally decided to get us in the loop, and we just told them guess what the transition period ends in a week. Needless to say, we're scrambling a bit. We can't merge as of 1/1/2024, we can't get the prior service provider to amend company B's plan to a safe harbor match plan for 2024 (understandably i guess). So now what? The plan is to merge Company B's plan (non-safe harbor calendar year plan) in to Company A's plan (our client, safe harbor match, calendar year plan). We're thinking the best option is to amend company A's plan to add company B as an adopting ER and bring all the employees of company B on to company A's plan as of 1/1/2024. Freeze Company B's plan i guess and take it over and then merger it as of 1/1/2025....

thank you so much for bringing this up, we did not even consider it that! The auditors having to audit 2023 anyway and the possibility of having the auditors do a simplified audit review.

I did see other posts about this question but still need clarification. We have a handful of large plan audits that fell under 100 participants with an acct balance as of 1/1/2023 but still have more than 80. All the plans in question filed as a large plan in 2022 (Schedule H audit etc). Based on our understanding of the 80-120 rule these clients can choose to continue to file as a large plan and file an audit OR they can choose to file as a small plan for 2023 and going forward until they go back up to 121 participants with a balance which will trigger an audit again. We highly doubt the clients in question will want to continue as a large plan to avoid the cost of an audit and therefore will want to file as a small plan starting in 2023. Our concern is the few that fell right under 100 (lets say 90-99). They may have to go back to an audit soon once they hit 121 again so we want to make this clear to them. We understand if they fall under to 79 they must file as small plan. Is our understanding correct?

Thank you Bird! That makes sense! Yes we're probably doing on an accrual basis so we'll use the 2021 contribution as a beginning balance. Thank you so much!

We're a bit confused on how the 5500 filings work for a retroactive plan. Background: We created a Defined Benefit Plan for 2021 by the clients corp due date in 2022. We're now working on the 5500 Tax Forms for the plan for 2021 and 2022. Please note we use Relius Gov't Forms. Question 1: Our understanding is we will need to do two separate forms using the 2022 5500 SF. One for 2021 and check off the retroactive option on the SF. However do we enter 1/1/2021-12/31/2021 as the plan year for this form? (this is what we do when we're using a prior year form to complete a final tax form so it makes sense). Question 2: the instructions are a bit confusing because they state that the prior year SB (2021) must be attached as an external attachment as well as the 2022 SB. Does this mean we should only complete one tax form and carry forward to the ending balance as of 12/31/2022. In other words do one tax form for 2022 mark off the retroactive box attach the 2021 SB as an external attachment and the 2022 SB. However, the 5500 SF would have a zero beginning balance and include all contributions for both years and ending balance as of 12/31/2022 (hope that maks sense :)) if this is correct, please ignore question one!

Example: 12/31/2022 payroll is deposited to the plan on 1/3/2023. The deposit includes deferrals, employer contribution, and loan repayments. We enter the deferrals and employer contributions under 1 (b) Receivables lines 1 & 2 on the schedule H and we usually enter the loan payments under (c) "other" receivable. We then lower the overall loan balance under C General Investment (8) Participant Loans by the receivable loan payment. However, I'm not sure if this is correct. Just curious on how everyone else handles receivable loan payments on the schedule H? Thanks!

Agreed! It's a very helpful tool, using this to determine what plans we have to add Roth Deferrals to to for the Secure 2.0 Roth Catch Up change😏🙂.

Reports>checklist data report. Choose create new query, select product on the top (for example Cycle 3). Check off any options you don't want included under output filters. I usually exclude amendment projects since you only want the exports from your documents I'm assuming. You will then need to choose the question in the checklist for Roth for example. Not sure what type of Relius Documents you use but for us that would be question under 22.0. Click on the checkbox for that question and then save, it will ask you if you want to save the query name so you can run the report again in the future. Click on next, on the top right-hand corner you will see three icons, excel, pdf, and csv. Choose excel...I usually receive an error message that the file may be corrupted but i click open anyway.