The description for Characteristic Code 2A changed a little from 2014 to 2015. It was just noted when preparing the 2016 return. I contacted EBSA who referred me to IRS since they created the codes. Neither EBSA or IRS would commit to a definition of Code 2A. I am interested in how Code 2A is being interpreted by those of you preparing Form 5500.
In the past, if the plan document had a new comparability profit sharing allocation method, we coded Form 5500 with "2A" regardless of whether the profit sharing component was funded for that year. Since it was a plan characteristic, we coded accordingly.
The new description reads, "Use this code if the employer contributions in the return year were based on one of the following allocation types-Age/service weighted or new comparability or similar plan, etc.
1) Do you interpret this to mean that you code with "2A" only IF the employer makes a profit sharing contribution IN THE RETURN YEAR?
2) Or do we continue to code with "2A" if the plan document has a new comparability profit sharing contribution provision and it does not matter whether this component is funded in a plan year?
My thoughts are if the plan has the provision, that is how it should be coded. We don't go back and forth with the code 2K when an employer match is made or not made from one year to the next.
Your thoughts please....Thank You!