pholosofizer Posted January 6, 2017 Posted January 6, 2017 Hi there! I have a plan that has always been an easy one to administer. Generally max out the top tier (and near max to execs) and give the minimum to others to pass gateway. *Plan excludes pre-entry comp* However, they hired a younger person in 2015 (and made enough comp to be an HCE in 2016) that became eligible in 2016. He is part of the tier that receives the max and his EBAR is through the roof. I won't be able to individually target young NHCEs because they are also lumped together (just 3 tiers in plan overall...hundreds of people). My question - can I use full year comp for everyone when running ABPT/calculating EBARs rather than plan comp? His EBAR would nearly cut in half. Gateway would still be using plan comp. Thanks!
BG5150 Posted January 6, 2017 Posted January 6, 2017 As long as his benefits are being calculated on partial year comp, I believe you can still test on any definition of comp that satisfies 414(s). QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
Mike Preston Posted January 6, 2017 Posted January 6, 2017 BG, why do you say what you say about "as long as"?
BG5150 Posted January 6, 2017 Posted January 6, 2017 10 minutes ago, Mike Preston said: BG, why do you say what you say about "as long as"? It was more of a "just make sure" kinda thing. But I guess if his benefit was calculated on a full year basis, the test would bomb just as bad. You just need to make sure your testing software is set up to do the test on full-year comp, but the allocation software uses participation comp. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
Mike Preston Posted January 6, 2017 Posted January 6, 2017 "I won't be able to individually target young NHCEs because they are also lumped together (just 3 tiers in plan overall...hundreds of people). " Have you considered letting the test fail and then adopting an 11(g) amendment which does exactly what you say you can't do? Doghouse 1
BG5150 Posted January 6, 2017 Posted January 6, 2017 ...and then amend the plan to everyone in their own group? John Feldt ERPA CPC QPA 1 QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
pholosofizer Posted January 6, 2017 Author Posted January 6, 2017 I'm going to just suggest they amend their allocation classes either way. For this year, I was able to accomplish everything they wanted with an additional ~$1000 to the lower tier group (which is a very small % of the total contribution). Thanks for the ideas!
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