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Posted

Anyone see any concerns with this structure:

New hires eligible to participate voluntarily after 90 days of employment.  Auto-enrollment kicks in after 12 months of employment for those who as of that date have not voluntarily enrolled.  

 

Posted

Any takers on this?  Although I haven't seen it done before and it seems like something that is likely to create mistakes, off the cuff I don't see any legal problems with it. 

Posted
35 minutes ago, jpod said:

Any takers on this?  Although I haven't seen it done before and it seems like something that is likely to create mistakes, off the cuff I don't see any legal problems with it. 

I don't think I have seen it before.  I agree that from administrative point of view its likely to be a headache and create problems.  Not sure about the legality.  

What is the reasoning for waiting a year for the auto-enroll?  Generally speaking,  the idea behind auto-enroll is to encourage savings by combating participant passivity and apathy.  Do they just want to make sure they are lazy for 12 months rather than 90 days?

 

 

Posted

No need to get into the "why" here.  Employer's mind is made up.

Posted

jpod, returning to your query:

Will the sponsor's desired design fit within the fill-in-the-blanks or further specifications allowed for the preapproved document the sponsor uses?

If not, will the sponsor pay for whatever document variation is needed?

 

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted

FGC:  Irrelevant to my question.

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