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Posted

I'm (attempting) to create a kind of decision tree / flowchart to easily figure out what tests need to be run on a given plan. That said, it's quite nuanced and I'm by no means an expert. I've added a picture of my progress so far. My company works exclusively with DC plans, over half of which are safe harbor. This is my first year doing testing so I very well could be mistaken about some things. Generally I've had my boss looking over things with me and helping me with what plans need what tests on a kind of case-by-case basis, but I'd love to just have a nice algorithmic way to figure it out. Any thoughts? Things I have wrong or need to add?

Black and White Yellow Blue Basic Decision Tree Whiteboard Brainstorm.png

Posted

While you may be "exclusively with DC plans", at some point you need to ask, "Is there another plan?" and "Is there a DB plan?"
 

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

Posted

I admire your initiative, thirst for knowledge, appreciation for the complexity, and desire to be efficient productive.  Certainly the time and effort to build out the chart is requires a lot of focus and is itself an learning experience.

Here are things to consider as you build out your chart:

Ask questions about the environment in which the plan lives:

  • Is there only one employer or are there other related employers who are or are not participating employers in the plan?
  • Does any employer sponsor another qualified retirement plan?
  • What is the type of the business of each employer (C-corp, S-corp, Sole Proprietor, Partnership, LLC, LLP...)?
  • Is this the first year that the plan is in existence?
  • Does the plan specify using Current Year ADP testing or Prior Year ADP testing?
  • Does the plan specify using Current Year ACP testing or Prior Year ACP testing?

Note that Top Heavy is a status of the plan and is determined as of the end of the preceding plan year, so ask if the plan is Top Heavy for this year before launching into allocations and compliance testing for this year.  Yes, you will want to determine the Top Heavy as of the end of this year so you will have the starting point for next year.

Check whether census data is complete and accurate.  There's nothing like doing all the work and finding out the census data is incomplete or inaccurate.

In many ways, the rules look at a plan not as a single plan but rather as three separate plans - elective deferrals, match, and non-elective employer contributions.  Each of these can have their eligibility, entry and allocation provisions.  Having a top-down hierarchy may not be the best work flow.

Complete the determination of HCEs up front. You will need this for just about everything.  You may want to have a separate procedure just for this.

If there are other related employers, check 410(b) coverage across all of the employers. (A failed test needs fixing and will have an impact on everything else.)

Keep in mind that forfeiture reallocations are annual additions that can impact the 415 limit.

These are just some random thoughts that may help you progress further.

Good luck!

 

Posted

I don't understand the Profit Sharing --> Yes -->  Type --> Match/NE

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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