Owner-only DB plan to freeze

[John Feldt ERPA CPC QPA]

The 100% owner is the only employee/participant and wants to freeze the DB plan.

Because this plan is not subject to ERISA, not 204(h) notice is required. Their advisor thinks it's required for all DB plans. Am I missing something?

[Belgarath]

I agree with you.

P.S. - Citations - Treasury Regulation 54.4980F-1, Q&A-3, which will also refer you to DOL reg. 2510-3.

[My 2 cents]

Model owner-only defined benefit plan 204(h) notice:

Memo to self: I held a meeting with myself and decided to freeze benefits under my plan. Therefore effective as of [date], I will not earn any additional benefit accruals under my plan. If I decide to resume accruals under my plan, I will let myself know.

[Belgarath]

If you have split personalities, does that make your other personalities employees for 204(h) purposes? What if SHUT UP YOU IDIOT who said that are you talking to me? no, I was talking to herBoys, Boys, please don't fight ##%%&^!**