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S Sorry for the long post.. our client A acquired Client B in 2013 and applied the transition rule through 2014 · The transition period expired at the end of 2015 · Client A sponsors a 401(k) plan which funds a match and service-based profit sharing contribution · Client A's 410b ratio and General ratios are below 70% and require ABPT · Client B sponsors a 403(b) and MPP · At the time of the acquisition, Client A informed us that the acquired group “lost its church status” and subsequently became subject to ERISA. Here are some of the questions that I have: · What contribution sources from the 403b/formerly-church-MPP would be included in the ABPT? They have 3 sources labeled “mandatory”, “matched”, and “voluntary”. Below are the source descriptions that have been provided. · Mandatory – 4% Employee contribution required to receive the 6% Match · Matched – 6% Employer Match · Voluntary – Employee contribution above 4% for eligible employees. Also includes voluntary EE contributions for those ineligible for match. All contributions are pretax. · Several employees have contributions over $18,000 – does this sound reasonable? · If the acquired company has lost its “church status”, does this have any other implications on the Client A plan beyond combined 402g and 415 limits? What exactly does it mean to have lost “church status”? Would both the 403(b) and the MPP be subject to 410(b) testing?
