BG5150 Posted December 20, 2021 Posted December 20, 2021 Plan allows for in-plan Roth rollovers at any time as long as the funds are 100% vested. Is this a protected benefit? QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
CuseFan Posted December 21, 2021 Posted December 21, 2021 But if you had in the plan, allowed an owner or HCE to take advantage of, and then amended out - you might have a discrimination issue, especially if the provision was not in the plan for a while, or was amended out before NHCEs became fully vested and were able to utilize. Luke Bailey 1 Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
Bri Posted December 21, 2021 Posted December 21, 2021 This IRS website page (blah blah blah not official guidance disclaimer dot dot dot) confirms it: https://www.irs.gov/retirement-plans/deadline-extended-to-add-new-in-plan-roth-rollover-provisions Luke Bailey 1
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