DB/K plan document

[Guest JohnCal]

Does anyone know of a document provider who has an approved DB/K prototype? Relius and Datair do not. Ft William says they do, but it is separate DB and 401k documents wrapped together with a third document. Just looking at options.

[frizzyguy]

Does anyone know of a document provider who has an approved DB/K prototype? Relius and Datair do not. Ft William says they do, but it is separate DB and 401k documents wrapped together with a third document. Just looking at options.

All a DB(k) plan is, and I would like others to chirp in because this is all opinion, a separate DB and 401k plan wrapped into one. The only reason that they might become popular is because you can maybe save on some administration fees. That being said, they are done so little (I've never heard of one in practice) that no one has an expertise, so for now they are actually going to cost the same, if not more than two seperate plans.

With DB plans, I like to stay ahead of the curve. I uncharacteriscally am going to let others break the ice with DB(k) plans.

I'm curious, do you have a client who wants one?

[Guest JohnCal]

Does anyone know of a document provider who has an approved DB/K prototype? Relius and Datair do not. Ft William says they do, but it is separate DB and 401k documents wrapped together with a third document. Just looking at options.

All a DB(k) plan is, and I would like others to chirp in because this is all opinion, a separate DB and 401k plan wrapped into one. The only reason that they might become popular is because you can maybe save on some administration fees. That being said, they are done so little (I've never heard of one in practice) that no one has an expertise, so for now they are actually going to cost the same, if not more than two seperate plans.

With DB plans, I like to stay ahead of the curve. I uncharacteriscally am going to let others break the ice with DB(k) plans.

I'm curious, do you have a client who wants one?

Apparently we do. One would think the plan design should be less expensive, but having to maintain three documents would probably negate that thought. I'm in the exploring mode right now, just curious if others have seen anything out there.

[shERPA]

There are just so many ways to design a DB plan superior to the DB/k, it's hard to imagine any practical application for one.

[Peanut Butter Man]

There is no document provider that has an approved DB/K plan document. The IRS has not pre-approved any DB/K plan document. Surprised the good people at FT William did not point you toward Section 7.07 of Rev. Proc. 2012-04, which says:

"The Service will consider § 414(x) in issuing determination letters for individually designed plans that consist of a defined benefit plan and a qualified cash or deferred arrangement. A § 414(x) combined plan sponsor must submit two Form 5300s and two applicable user fees."

http://www.irs.gov/irb/2012-01_IRB/ar11.html

[FAPInJax]

My understanding is that there is usually a wrap around a DB and 401(k) document (this being the best way to maintain language necessary for each). Administratively, I do not see a reduction in costs because the 401(k) still has to be administered and then the DB. I agree with the one poster in that I have never seen one in practice but it definitely appears that a 401(k) costs the same or more than 2 plans - 401(k) and DB - separately.

[mwyatt]

Looked like a "bright" idea when posited in PPA; however, IRS's position that you take two documents that could be maintained as prototypes/volume submitters (with $0 IRS User fees and presumably smaller preparation costs since using preapproved documents) and now have to treat the combined group of documents as two individually designed filings (for a once ever five year combined IRS User fee of $5,000) takes some of the luster off of this idea.

Hard pressed to see what cost savings would be accomplished by layering in what amounts to an annual fee to the IRS of $1,000 for the document.