oldman Posted September 4, 2014 Posted September 4, 2014 We have a non-governmental 403(b) plan with just pre-tax and after-tax contributions. Is the plan considered an ERISA plan and required to perform ACP testing?
rcline46 Posted September 4, 2014 Posted September 4, 2014 How many investment providers do they have? Who rules on hardships and/or loans? The DOL published how to avoid being an ERISA plan back in 2009 I believe.
30Rock Posted September 4, 2014 Posted September 4, 2014 Voluntary after tax could blow the exemption. Need to review the DOL opinions.
Belgarath Posted September 5, 2014 Posted September 5, 2014 Specifically, take a look at FAB's 2009-02 and 2010-01, and the regulation 2510.3-2(f).
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