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Showing results for tags 'safe harbor notice'.
Found 3 results
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For our plans that have the "maybe" safe harbor, we have always provided the client wanting safe harbor treatment the notice saying they will fund the 3%, the maybe notice for next year and the amendment 30-90 days prior to the end of the year. I assume that process does not change with all the new Safe harbor rules. I know there are new rules about declaring safe harbor treatment into the next year. I'm concerned about what needs to be done this year for these "maybe" safe harbor plans. Can it be simplified such as - ignore this year end and provide a notice next year up to Nov 30 for 2020?
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We are part of a CPA firm, and perform plan administration and reporting services for clients of the firm. Mid-2019 we billed plan sponsor for 2019 plan work. Plan Sponsor was not happy with the amount of the bill and told CPA they were going to find someone else to do TPA work, but CPA would continue to do their accounting and tax work. Today we learn they did not like other TPA options and so decided to stay with us. Unfortunately, they did not inform us (or the CPA) of that decision. They want us to continue to perform TPA work and reporting for their plan for 2019 and going forward. During the time we thought we were fired for TPA work, we prepared the SH notices for our clients, but did not prepare one for this particular client, thinking they had another TPA doing their retirement plan work. So I think it is highly probably that no SH notice was distributed to participants. They have had a SH 401(k) plan for several years, and deposit the SH contribution along with the employee deferrals every pay period. Can they still be a SH plan for 2020? Any options?? Thanks!
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Greetings 401k Board, I am hoping for feedback and guidance regarding an unusual situation. Employer A is about to acquire Employer B. Both parties agree that Employer B will terminate their Safe Harbor plan prior to acquisition (closing in less than 30 days). Is there an exception to the testing requirement for the current year (because of elimination of the SH) due to plan termination? They will have made 11/12 months worth of SH accruals, and there will no longer be a plan for the final month. They will be able to timely issue a "NO 2016 SH" notice, for what it's worth. As an added complexity... If the deal falls through after after 11/30, can Employer B re-issue an updated SH notice to re-institue the 2016 SH contribution? It will certainly be an employee-friendly change, and be done with some time to allow employees to consider the elections for 2016. That's what the 30 day period is intended for if I'm not mistaken. Any observations, questions, input are appreciated! Thanks!
