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5500 Line 6 Count - Active Employees No Longer Eligible for Contributions


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Posted

We have separate 401(k) plans for non-union and union employees.  How are employees who unionized but with a balance in the non-union plan counted on line 6?  Are they active because they are active employees or are they separated because they are now in a different plan?

Thanks in advance.

Posted

still active

The definition of retired/separated in the instructions says

"i.e., individuals who are retired or separated from employment covered by the plan...."

and although that hints at some leeway since "hey does the union job no longer mean covered by the plan?", I think it's generally accepted they count among the actives while their employment with the sponsor is active.

Posted
4 hours ago, Bri said:

still active

100% correct. If retired/separated they'd be eligible for distribution - which they are not. They simply wend from an eligible class of employee to an ineligible class of employee, but they are still employed by the employer (or any control group member) maintaining the plan.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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