cpc0506 Posted October 5, 2015 Posted October 5, 2015 402(k) Plan contains a life insurance policy for one of the HCE. The policy is in the name of the plan. The participant for whom the policy exists has been paying the insurance premiums himself. Is this allowed? If so, how do you account for the payments within the Trust Accounting for the plan?
Bird Posted October 5, 2015 Posted October 5, 2015 The participant for whom the policy exists has been paying the insurance premiums himself. Is this allowed? You mean with personal money? Of course not. (Unless the plan allows for after-tax contributions, which of course it does not, and would raise other issues...) I'm not sure how to fix it. I suppose I would look at it as if the individual has been lending money to the plan, which has its own set of problems. The first thing you do is figure out who paying to fix the mess and get some money up front. Ed Snyder
david rigby Posted October 5, 2015 Posted October 5, 2015 What is your relationship to the plan? to the Plan Administrator? Assuming it's only a typo, and you mean 401(k) plan, if you are the TPA, perhaps you will want to express an opinion and then back out, saying this is a job for the plan's ERISA counsel. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
cpc0506 Posted October 5, 2015 Author Posted October 5, 2015 Sorry. This is a 401k plan. My typo. No, it does not allow for after-tax contributions. We are the TPA. The participant with the life insurance policy is a greater than 5% owner.
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