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Posted

We have a 401(k) plan converting to us from a different TPA/Recordkeeper right now. In their plan, they have some money purchase pension plan assets that were rolled over into the 401k plan at some point. Do these assets need to be included in top heavy testing? What should we make sure we do to classify these correctly?

Posted
59 minutes ago, Bill Presson said:

Were they rolled over or merged into the plan?

We're still straightening out the details as both the prior TPA and the client are... well, not the most informed on how things work, and aren't getting us all the information. That said, this is the first plan we've ever seen money purchase pension assets in and it's for many people, so we're fairly certain it was merged.

Posted

If it was a merger they are in TH testing like any other type of plan being merged into another plan.  

Also, don't forget a merger will mean protected benefits.  These assets are in a type of pension plan and for these payments a person has to be offered J&S annuities of various types as a form of payment.  They can opt for a lump sum, and most people will do so,  but this is the big hassle of these plans if it is a merger.  These assets still have just about all the restrictions on them as if they are in an MPP still.  

Do your homework.   

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