waid10 Posted March 11, 2020 Posted March 11, 2020 Hi. I need help understanding how the 415 limits work with multiple plans. We are a local governmental entity. We have a 457 plan and a 401a plan. We have a participant that defers the max allowed to his 457 plan account ($19,500) and catch-up ($6,500). I know that the catch-up is not taken into account with the 415 limit ($57,000). Does that mean that the $57,000 limit is imposed on the 457 deferrals and any contributions he receives under the 401a plan? In other words, he could receive up to $37,500 in employer contributions in the 401a plan, correct? Thanks.
CuseFan Posted March 11, 2020 Posted March 11, 2020 I do not work with government plans so I'm not sure on the coordination between 457(b) and 401(a) - but in the private sector, you could have 401(k) deferrals of $19,500 (plus catch-up if eligible) and yes, $37,500 in employer contributions taking you up to the $57,000 415 limit. I cannot see your arrangement being limited to anything less than that, I'm fairly certain. Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
spiritrider Posted March 12, 2020 Posted March 12, 2020 A 457 plan is not a qualified plan. 457 employee deferrals are not included in the 402g employee deferral limit. Total 457 (employee + employer) contributions are limited to the same amount as the employee deferral limit and are not included in the 415c annual addition limit. Also, 401a mandatory contributions are not considered employee deferrals and are not included in the 402g employee deferral limit.
waid10 Posted March 12, 2020 Author Posted March 12, 2020 10 hours ago, spiritrider said: A 457 plan is not a qualified plan. 457 employee deferrals are not included in the 402g employee deferral limit. Total 457 (employee + employer) contributions are limited to the same amount as the employee deferral limit and are not included in the 415c annual addition limit. Also, 401a mandatory contributions are not considered employee deferrals and are not included in the 402g employee deferral limit. wait, is this true? I was aware that a 457 plan is not subject to the 402g limit. But it just happens that the 402g limit is the same $19,500 dollar amount as the 457 limit. But my understanding is that the 457 contributions are taken into account for purposes of 415. It sounds like you are saying this isn't true. If I understand you correctly, you are saying that a participant could defer $19,500 in the 457 plan, and then also receive as much as $57,000 in contributions under the 401a plan. Is that correct?
John Feldt ERPA CPC QPA Posted March 12, 2020 Posted March 12, 2020 If age 50 or older, and the plan allows the age 50 catch-up, in 2020 they can defer $26,000 in the 457(b) plan, plus they can receive an employer allocation in the 401a plan of $57,000. Assuming the plan provisions allow. 415 does not take into account any 457(b) allocations.
Ellie Lowder Posted March 16, 2020 Posted March 16, 2020 And, if they also have a 403(b) plan, there is also a separate $57,000 415(c) limit for employer contributions - so, $57,000 for the 401(a) DC plan; another $57,000 for the 403(b) plan. And, as John says, the 457 nothing to do with any of them.
JonC Posted March 16, 2020 Posted March 16, 2020 On 3/12/2020 at 9:09 AM, waid10 said: wait, is this true? I was aware that a 457 plan is not subject to the 402g limit. But it just happens that the 402g limit is the same $19,500 dollar amount as the 457 limit. But my understanding is that the 457 contributions are taken into account for purposes of 415. It sounds like you are saying this isn't true. If I understand you correctly, you are saying that a participant could defer $19,500 in the 457 plan, and then also receive as much as $57,000 in contributions under the 401a plan. Is that correct? That's correct. You (very) occasionally see participants eligible for both 457 and 403(b) or 401(k) (governmental 401(k) plans are rare but do exist) and participants contribute up to $19,500 in each plan.
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