imchipbrown Posted March 7, 2002 Posted March 7, 2002 Have a few clients which have comingled MP/PS assets. One I'm merging has no NHCEs. I'm toying with the idea of drafting currently dated minutes stating the MP and PS were merged, effective retroactively to 12/31/01. Just trying to get a final 5500 in 2001, otherwise 2002 is fine as well. We don't want to back-date anything. Any thoughts? Chip Brown
Blinky the 3-eyed Fish Posted March 8, 2002 Posted March 8, 2002 You can't retroactively merge the plans. I would be tantamount to retroactively terminating a plan, which we all know is not allowable. Also, upon the MP merger into the PS, a 204(h) notice must be issued. "What's in the big salad?" "Big lettuce, big carrots, tomatoes like volleyballs."
david rigby Posted March 8, 2002 Posted March 8, 2002 I think the merger is not what triggers a 204(h) notice, but a change in the rate of future employer contributions. This might occur on merger, but it may have already occurred if the plan was frozen earlier. If so, one hopes that the notice was given then. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
Blinky the 3-eyed Fish Posted March 8, 2002 Posted March 8, 2002 Pax, you are correct. I was merely pointing out that upon the plan merger the future rate of accruals in the MP plan would be most likely reduced and thus a 204(h) notice would be needed. "What's in the big salad?" "Big lettuce, big carrots, tomatoes like volleyballs."
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