403(b)/401(k) aggregation REDUX!!! ? New rules?

https://www.businessofbenefits.com/2018/03/articles/403b/a-403b-psuedomorph-the-irss-gradual-shift-on-applying-415-limits-to-403b-plans/

SpiritRider...you've chimed in on this issue time after time and have been very helpful with respect to this issue of aggregating 403(b) contributions with non-affiliated group retirement plans. Do the details in the above article change the rules somewhat, such that there is no longer concern about having to aggregate the total employee + employer limit for a 403(b) participant.

In prior discussions, you have stated that I am considered an "owner" of my hospital-based 403(b) plan and, as such, would be limited with respect to solo-401k contributions I could make from my side income to a total of $55,000, due to aggregation rules. Does this no longer hold true?

Anyone else have an opinion.

Thanks, in advance, to the very smart and informative folks on this board (especially you, SpiritRider!)

Scarabrad

My quick read of the article leads me to the conclusion that the author is narrowly discussing aggregation of 403(b) with 403(b).  I don't think the article is saying anything with respect to aggregation of 403(b) with 401(a). I could be reading it wrong.

Yeah, this is only saying that multiple 403(b) plans of a single employer (not the employee, who used to be considered the employer) are aggregated for annual additions. What's new about that I guess is not that a single employer's 403(b)s needed to be aggregated for 415 but that there is no longer a requirement that each employee's 415 limit consider 403(b)s of yet other unrelated  employers. Probably a widely ignored rule anyway - who asks their 403(b) clients for information regarding employees participating in unrelated employer 403(b) plans?

If you go to pub 571 you'll see the familiar rule re qualified plans and common control two paragraphs after the one sited - unchanged, as far as I can tell.

4 hours ago, lippy said:

 Probably a widely ignored rule anyway - who asks their 403(b) clients for information regarding employees participating in unrelated employer 403(b) plans?

Yep, the rule had caught me sleeping about 13 or so years ago when I had to answer questions about an individual (let's say a doctor or professor) in a 403(b) who wanted to fund a SEP through their self-employment income.  

I guess it's okay now, but many have been doing it over the past as if the rule never existed 

Good to know.  I was just made aware of this change this morning.  Almost got caught sleeping again.  I'm glad it's settled. 

Agree that this appears to be for, for example, the doctor who works for several different 403(b)-providing entities like two different medical centers. It is an important change that we have been teaching the old rule for years. Good on Bob Toth and Evan Giller and you Scarabrad for pointing this out (both my kids are doctors).