Gadgetfreak Posted March 1, 2023 Posted March 1, 2023 Does anyone know if participants that become eligible because of the LTPT rules will ALSO need to be follow the EACA rules? ERPA, QPA, QKA
C. B. Zeller Posted March 1, 2023 Posted March 1, 2023 Are you asking whether a plan which is an EACA could exclude LTPT employees from automatic enrollment without violating the EACA uniformity requirement? We don't have any guidance from the IRS on this, but my guess would be no. Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance. Corey B. Zeller, MSEA, CPC, QPA, QKA Preferred Pension Planning Corp.corey@pppc.co
Gadgetfreak Posted March 1, 2023 Author Posted March 1, 2023 Yes. That is what I am asking. We know that most new plans over 10 EEs will need an EACA. We also know about the new LTPT rules that start in 2024 require that sponsors allow LTPT EEs to defer but are not required to give an employer contribution. I thought that it might be possible that they would also be exempt from the EACA rules. Of course, I also confirmed that, should an LTPT end up having a balance, they WILL count in the new calculations for an audit requirement. ERPA, QPA, QKA
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