Controlled Groups issues

[Guest DazedAndConfused]

Hi - We took on a couple of plans that are a controlled group. Can anyone steer me towards where I can find information on controlled group issues? I am not as familiar as I would like to be on this subject. Thanks!

[Effen]

Any pension service will give you lots of information about controlled groups. It's a fairly major topic.

Basically, if it is a controlled group, you treat the entire group as if it is one employer. Do you have a specific question?

[Guest DazedAndConfused]

Any pension service will give you lots of information about controlled groups. It's a fairly major topic.

Basically, if it is a controlled group, you treat the entire group as if it is one employer. Do you have a specific question?

I am just looking to brush up on what little I know. I am looking for more for something to read, not a service. I don't have any specific questions. Something that will tell me what tests I need to look for. How to treat them differently than a single employer plan.

[Effen]

I googled "controled group" and got about a billion hits. This first one looked pretty good.

http://www.employerbook.com/CGCode.html

Pension Answer Book is good, CCH, RIA, BNA all have summaries I'm sure.

[Guest DazedAndConfused]

I googled "controled group" and got about a billion hits. This first one looked pretty good.

http://www.employerbook.com/CGCode.html

Pension Answer Book is good, CCH, RIA, BNA all have summaries I'm sure.

Thank you so much! This is perfect!

[jpod]

DazedandConfused: Allow me to suggest that you don't need to read much in order to service the plans which you know are controlled group plans. To the contrary, what you need to worry about is whether a plan is in fact a controlled group plan if nobody told you it was a controlled group plan (and by "controlled group" I am including affiliated service groups too). This is a potential liability issue for you and your firm; you need to know exactly what you're dealing with at (or prior to) the commencement of your engagement.

[Guest Boilerburm1]

Plugging someone else's book, I reference "Who's the Employer" by Darrin Watson for these types of issues. He does a great job of spelling out the complications and real world applications of controlled group and affiliated service rules.

[Guest DazedAndConfused]

DazedandConfused: Allow me to suggest that you don't need to read much in order to service the plans which you know are controlled group plans. To the contrary, what you need to worry about is whether a plan is in fact a controlled group plan if nobody told you it was a controlled group plan (and by "controlled group" I am including affiliated service groups too). This is a potential liability issue for you and your firm; you need to know exactly what you're dealing with at (or prior to) the commencement of your engagement.

There definitely is a controlled group. It is in their documents as such and the ownership shows it as such. I just wanted to make sure there were not any additional testing that would need to be done that I am missing. I am gathering that I only really need to do the normal testing but doing the testing on all the plans together.

[rcline46]

Testing all plans together is the 'safe' way, but not the only way! Of course if testing together and all tests pass no need for anything else. But if you have a failure, life becomes interesting.

Can you say 410(b) group? Can you say 'required aggregation group' or 'permissive aggregation group'? What if the plans of the members of the CG have different plan year ends? You need to read the regulations carefully if any of these items crop up.

[Guest DazedAndConfused]

Testing all plans together is the 'safe' way, but not the only way! Of course if testing together and all tests pass no need for anything else. But if you have a failure, life becomes interesting.

Can you say 410(b) group? Can you say 'required aggregation group' or 'permissive aggregation group'? What if the plans of the members of the CG have different plan year ends? You need to read the regulations carefully if any of these items crop up.

This is why I am asking - Do you have something I can read to read up on the regs? I am asking for help here.

[Effen]

Dazed, I admire your desire to learn and make yourself into a better benefits consultant, but honestly, it seems like you are in way over your head. The fact you don't even know where to start looking for the answers to these questions tells me you are either in a shop where you don't get a lot of support, or you are just the type of person who likes to ask first and look second.

These are the types of issues that can lead to law suits if your advice to the client is not correct, so be careful. You seem like you are at a stage in your career where you don't know what you don't know and that can be very dangerous. You should be asking these questions to those inside your office, and if you don't have anyone in the office who knows, you probably shouldn't be taking this assignment.

[rcline46]

All I can say is to read the regulations. Also obtain a copy of the Pension Outline book by Sal Tripodi. All of these issues are discussed in detail in the Pension Outline book. There is no short cut, no 'Cliff Notes' version.

[Guest DazedAndConfused]

All I can say is to read the regulations. Also obtain a copy of the Pension Outline book by Sal Tripodi. All of these issues are discussed in detail in the Pension Outline book. There is no short cut, no 'Cliff Notes' version.

I wasn't looking for any shortcuts, just wanted to cover all my bases. I have been reading all of these books. I know the basics, just wanted to make sure nothing really changed & that I knew what I was doing.

[Guest Boilerburm1]

I agree with what Effen is saying - be careful. It is just as wrong to test groups together when it isn't appropriate as it is to test them separate when they should be tested together.

If you are responsible for the testing, you should know the employer. This would entail knowing what the testing group is supposed to be. The only way to do this is to thoroughly understand the ownership of the entities involved and how the controlled group rules work.

Again, since you say you are asking for help, I will say that "Who's the Employer" by Derrin Watson is a great place to go to dig into these issues and truly understand how these requirements work.

Good luck.

[Jim Chad]

"Who's the Employer?" by Derrin Watson is a great book on the subject. If you add to it the "Coverage and Nondiscrimination Answer Book from Panal publishers, by Tom Poje and Amy Cavanaugh,you will have it all.