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Found 2 results

  1. We have a cash balance plan that set a termination date in September this year. We permissively aggregate the DB and DC plan each year to pass general testing. Does the plan termination date create a short plan year for the DB plan and does that now make the two plans unable to be aggregated due to differing plan years or is amending the plan to terminate 9/30/2023 not creating a short plan year for testing purposes? No assets will be distributed this year and both plans define the limitation year as the plan year. I don’t believe the regs are concrete on this scenario and that it could be interpreted as being a short plan year. But it could also be interpreted as being a short plan year only during the year when the assets are distributed not necessarily when the plan term date is effective. Secondly If the DC plan is terminated 9/30 as well, I’m thinking it would be reasonable to aggregate them under this scenario? Thank you!
  2. Does someone know if this is allowed or not? In my ASPPA books it only addresses the fact that deferrals can be recharacterized after failing the ADP Test. Not whether the individual is the HCE getting the refund. Here is the scenario: 2 HCEs: The top paid/ highest deferring HCE is not eligible for catch-up (under 50). He is the only HCE required to do a refund under the failed ADP test correction. The other HCE is elegible for catch-up. He only deferred $7,500, so by using catch-up on him we could make his deferral rate go way down. All in all, even by doing this they would still fail the ADP test. They would fail by a much lesser amount, which would significantly decrease the refund needed for the top HCE. Does the HCE have to need a refund for the catch-up recharacterization after failing the ADP Test, or does the ADP test just need to fail and all HCEs' who are catch-up eligible can have their deferrals recharacterized if possible? Thanks in advance!
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