metsfan026 Posted March 8, 2023 Posted March 8, 2023 If there are no HCE's who are left participating in a DB/DC combo plan (an odd situation, I know, and it may just be a 1 year aberration), how would that impact the Gateway? Is it still the 7.5% or can that be reduced dramatically? The employer is going through some turmoil and change over so just want to make sure what we can/can't do. Thanks in advance
Popular Post C. B. Zeller Posted March 8, 2023 Popular Post Posted March 8, 2023 If no HCEs benefit in the plan, then the plan automatically satisfies 401(a)(4), including the gateway. ugueth, Bill Presson, acm_acm and 2 others 5 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
metsfan026 Posted March 8, 2023 Author Posted March 8, 2023 7 minutes ago, C. B. Zeller said: If no HCEs benefit in the plan, then the plan automatically satisfies 401(a)(4), including the gateway. What if one is eligible, but opting out of the PS/CB)? So they are getting $0 from either the DB and DC? If there were no contributions, can the DB be $0? What if there was an HCE who made just an Employee Deferral and received a SH match? Does that still mean the Profit Sharing could be $0? I just want to confirm I have all of my ducks in a row.
Lou S. Posted March 8, 2023 Posted March 8, 2023 How does an eligible participant "opt out from year to year" on a CB plan? Either you satisfy the accrual requirement and get a benefit or your don't, it's not a CODA. But assuming that there was some amendment timely and properly executed such that no HCE benefits under the plan, or no HCE worked enough hours to accrue a benefit, then as CB Zeller pointed out you will automatically pass gateway and 404(a) because the HCE rate is going to be $0 and 0%. Assuming the Plan's are not top heavy then if no HCE benefits for PS or CB than your PS could be $0. If the combo plan is top-heavy, RTD on how you satisfy that in your specific situation. Bill Presson, acm_acm, Bri and 1 other 4
Recommended Posts
Create an account or sign in to comment
You need to be a member in order to leave a comment
Create an account
Sign up for a new account in our community. It's easy!
Register a new accountSign in
Already have an account? Sign in here.
Sign In Now