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Guest PCS Inc
Posted

We have historically worked mainly with 401k and 401a plans but are in the position to take over a current client's Non-Erisa 403b plan and add an employer match to it. My understanding is that this new plan would no longer be Non-Erisa, would be subject to annual 5500 reporting, would require a Plan Document and SPD and the match would be subject to ACP testing. Is this correct? What else do I need to know about 403bs that differs from the 401k atmosphere?

If my assumptions above are correct, for the 5500, would only the employer portion of the plan assets be required to be reported on or would the entire plan assets, including 403b accounts need to be reported?

Also, can the participants have their matching contributions sent along with their deferrals to the annuity or MF of their choice or do they need to be invested separately? (the contributions will be 100% vested)

Finally, would employee benefit statements be required for participants other than what is given to them by their annuity or MF company?

Posted

That is true under current rules but the DOL has proposed full 5500 reporting beginning in 2008. Also IRS plans to revise the 403(b) regs effective for 2008 which will require extensive changes to plan documents and administration.

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