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Found 3 results

  1. We are looking into taking over the third party administration of a plan that currently has a QACA that utilizes the 3% non-elective contribution safe harbor method that vests after two years of vesting service. We are exploring changing the ADP safe harbor method to traditional 3% non-elective which is 100% vested immediately, but if the administrator is already successfully administering the QACA, I am thinking this may not be in their best interest? I think my question is, "is the ability to administer the QACA properly the only difference between a two year difference in vesting requirement, or are there other considerations?" A two year vesting schedule seems like a huge benefit for a small trade-off. The end goal of the program design is to add nonsafe harbor non-elective contributions to the plan and potentially also adopt a DB plan, I want to use the QACA safe harbor contributions towards top-heavy and 401(a) testing if i can, and if it makes sense to continue to maintain the QACA.
  2. Employer terminating 401K 6/30/2017, no employee contributions after that date. Can safe harbor for 2016 be made by 9/15, which is after the termination date w/o jeopardizing the plan term?
  3. Hoping someone can enlighten me Plan is Safe Harbor Non-Elective 3%.(SHNE) Age and service waived as of 1/1 for NON-seasonal employees. Seasonal Employees are always excluded. Eligibility is 21 and 1 year of service (1000 hours in 12 month period) with dual entry 1/1 and 7/1 I'm being told that as long as the Plan can pass coverage then the Seasonal employees will NOT receive a SHNE contribution even if they have met the 21/1 year and entry requirements. Something doesn't seem right - isn't this the very definition of discriminatory? The Seasonal people are not covered under a different Plan. How does one go about defining Seasonal? Do you write a very specific definition into your Plan Documents? The client grows different crops and there are 3 seasons. Can you exclude one season (say Summer season) and not Fall and Spring?
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