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Posted

If the document states the interest rate assumption for testing is hard coded in the document as 7%, could an amendment be made after the plan year end to change it to 8.5%?

Posted

assuming it is a DC plan, you have to use an interest rate between 7.5 and 8.5, so that implies you have a document not in conformity with the regs.

(1.401(a)(4)-12 definitions (Standard interest rate)

why a document would lock into an 'assumption' is beyong me. if I was to amend I wouldn't have an assumptions be hard coded.

I would hold you have to follow the terms of the document - if you change the interest rate assumption then either the HCE can get a larger contribution or the nhces could end up with a smaller contribution and still pass testing. that would seem to be changing the allocation, which would be impermissible. in other words, if I failed testing at 7% but would pass at 8.5% I would think you have to increase the NHCEs contribution first.

I think IMHO means

In My Hartnett Opinion :D

Posted

SSEWBA

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

Posted

The only reason I can think of to put testing assumptions in your plan is as part of a fail safe allocation formula. If that is the case, changing the assumption will affect the operation of the fail safe language ... in effect chaanging the allocation... impermissibly ... but I'm just guessing (BIJG?)

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