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Found 3 results

  1. I think this is correct, but as a sanity check since it seems harder than expect to find authority on this - if a 401(k) plan is frozen, it's still permissible for participants to take out new loans and hardship withdrawals, correct?
  2. A plan was frozen 2017 with no accruals that year. Doing a 401a26 test under average accruals to date as of 1/1/2017 it passes for 2017. The plan is formally terminated in 2018 and paid out. Does the plan have to pass 401a26 for 2018?
  3. Is there a discrimination issue with freezing a CB plan where the only HCE/Key has fully accrued benefits, and the other participants have not? It is a small plan, just a handful of participants, and the owner won't receive any additional benefit accruals, so any contributions will really be going towards the other participants. No accrued benefits would be cut back, but I feel like freezing the plan would disproportionately affect the NHCE since they would be the ones losing out on the possibility of future accruals. But I seem to think that it doesn't matter, since the plan could terminate, in which case the result would be the same. I apologize in advance, my knowledge of cash balance plans is obviously very limited. Thoughts?
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