Schedule T, item 4e

[Guest BAR]

What do we call Safe harbor disaggregated portion of the plan for item 4e of Schedule T. This plan also has a profit sharing contribution therefore I already have a disaggregated portion called "nonelective".

[R. Butler]

We have just called it "safe harbor nonelective".

[wmyer]

If it's the 3% non-elective component, we call it "nonelective." If it's the safe harbor match or enhanced match, we call it "401(m)." Last year, when the new version of the 5500 first came out, I placed numerous queries and even put a post up on benefitslink about this, and this seemed to be the right thing to do.

[Guest BAR]

wmyer,

So it it okay to have more than one portion of plan labeled "nonelective"?

[Tom Poje]

it should be, for thats what it is - a nonelective.

you could have:

Qualified nonelective (QNEC)

Safe Harbor nonelective

nonelctive (normal profit sharing)

but they are still all nonelctives.

[Kristina]

Ahem. The instructions say "the disaggregated part of the plan to which the information on lines 4c and 4d pertains as follows: "nonelective", "401(k)", "401(m)", "ESOP", "Non-ESOP", "Excludable", "Nonexcludable". ... If entering information on life 4e, identify the disaggregated part(s) of the plan as follows: "nonelective", "401(k)", "401(m)", "ESOP", "Non-ESOP", "Excludable", "Nonexcludable"."

Why are you considering the QNEC and safe harbor contributions as disaggregated?

[Tom Poje]

perhaps my response was unclear. I don't disagregate the nonelectives. I was merely indicating that a nonelective is not simply the run of the mill profit sharing, but can include other items.

[Kristina]

Oops. Too many casual message boards. Didn't mean to step on toes.

The way I read the earlier posts, it read as though they were going to great lengths to identify all contributions separately, which would be disaggregating. Not necessary.

[Guest BAR]

The reason I had to disaggregate the "3% safe harbor" nonelective, from the remaining portion of the nonelective is because they each have separate benefit accrual requirements, thus different ratio percentages. I just wanted to know if it is okay to list "nonelective" more than once on the schedule.

[Tom Poje]

my understanding is that you wouldn't have separate listings, even though you had different accrual requirements.

remember, schedule T is for coverage.

as an example, suppose I had a mp plan and a ps plan, each with different formuals.

I am allowed to aggregate the plans for coverage purposes.

with a single plan you still have your nonelective contribution - actually you indicated you have two - one that is a 'special' nonelective, so to speak, but it is still a non elective - whether it is a QNEC or a SHNEC or whatever. A typical cross testing plan today would be a safe harbor 401k with a shnec and an additional ps contribution for the owners only. if you were to test coverage how you desire (one coverage test for the SHNEC and another for the PS) you would never pass the ps.

so you end up passing coverage, but now you have to pass amounts testing.