Combo Plans & DC Document

[SoCalActuary]

We have both DB & DC plans together, and are cross-testing to prove compliance.

The VP document for the DC plan provides a Gateway language with a 5% rate built-in.

But we need something more. When a DB is involved, the amount may go to 7.5%.

Or we may find that some employees need a higher contribution than others, possibly because

some are not covered in the DB plan.

For the participants with no DB benefits, I would like to have one gateway amount.

When the participants also have DB, I would like to use a different amount, based on the average

DB contribution rate for all NHCEs.

Does Corbel's document have this option?

Does anyone else have any suggestions?

[John Feldt ERPA CPC QPA]

We have resorted to writing the language ourselves to modify the Sungard language.

When we talked to Steve Forbes at Sungard, he indicated that they did not have language that they could simply provide to us (even though we are on their maintenance plans for DB and DC prototypes and for their DC volume submitter). He recommended that the Gateway amendment page be modified (of course).

For each DB/DC combo, we pay close attention to that gateway language. Depending on how the plan design is finalized, we have added language to use 7.5% (or language for something less if we are offsetting the gateway by the DB accruals, or other language as needed).

Then, because of our changes, we have new clients sign that amendment when they adopt the plan.