Relief measures for Safe Harbor Match Plans

Has there been any relief measures put into place for Safe Harbor Match Plans that are also Top Heavy?  Company is looking for ways to manage their costs during this time.

TIA

Not yet. ARA has requested it, but nothing authorized.

WCP

Mr. Presson, is it fair to say that this relief is doubtful?  Or are there any signs that suggest this might happen?  I have seen none.  Just rumors and such....  Thanks!

1 hour ago, Below Ground said:

Mr. Presson, is it fair to say that this relief is doubtful?  Or are there any signs that suggest this might happen?  I have seen none.  Just rumors and such....  Thanks!

 

I think it's doubtful but that is a personal opinion from someone with no inside knowledge.  Why would the IRS decide to let TH plans avoid TH Minimums for 2020?  As you probably know, if the plan is calculating the SH match less frequently than annually, the funding is due no later than the last day of the Q following the Q for which the match is calculated.  You can amend this mid-year to an annual match calculation.  This will never result in a decrease in the amount of the SH MC due for a particular participant - in fact many times their SH Match will increase for the year.  Why would you do this if you are trying to manage expenses?  Because your SH match will then be due by the due date of the employers tax return, including extensions.  This would allow the employer to defer the SHMC deposits for a year or more and help with cash flow.  Another personal opinion, this time next year, this will all be nothing but confusing history and a boat load of good faith amendment requirements.

The relief would need to be from Congress.

17 hours ago, Below Ground said:

Mr. Presson, is it fair to say that this relief is doubtful?  Or are there any signs that suggest this might happen?  I have seen none.  Just rumors and such....  Thanks!

 

BG, As Luke says, the relief would have to come from Congress and who knows what they will do. Nevin posted an article today that there's a bill introduced to temporarily increase the DC contribution limits, so it seems everything is in the mix.

WCP

Hmmmmm.  I guess my post was poorly worded?  My actual intent was more like "is there any reason to think this type of relief will be provided".  (In my personal opinion I would think not.)  Knowing that many others are more plugged into the political side of our business, I thought that maybe something was in the works that I was unaware of.

As a side remark, I have found posts by Luke Bailey to always be thoughtful with exceptional insight.  On several occasions I have listed posters whom I believe are people who can be counted on to make posts which are always worth reading.  That list has always included Mr. Bill Presson; and Mr. Bailey for that matter.

So if you do run across any inside information, please let us know.  As I am sure you would do without my 2 cents.

Thanks BG. I'm hearing that this is still under consideration. But nothing official yet.

1 hour ago, Below Ground said:

Hmmmmm.  I guess my post was poorly worded?  My actual intent was more like "is there any reason to think this type of relief will be provided".  (In my personal opinion I would think not.)  Knowing that many others are more plugged into the political side of our business, I thought that maybe something was in the works that I was unaware of.

As a side remark, I have found posts by Luke Bailey to always be thoughtful with exceptional insight.  On several occasions I have listed posters whom I believe are people who can be counted on to make posts which are always worth reading.  That list has always included Mr. Bill Presson; and Mr. Bailey for that matter.

So if you do run across any inside information, please let us know.  As I am sure you would do without my 2 cents.

Thanks, BG. I regret I am not personally plugged in politically, although I know a few folks who are.

I think this is kinda what we were hoping for.

https://www.asppa-net.org/news/irs-issues-guidance-mid-year-amendments-certain-safe-harbor-plans?utm_source=MagnetMail&utm_medium=email&utm_term=bpresson@egps.com&utm_content=COM_APPA_eNews_06.29.2020_MON&utm_campaign=BREAKING NEWS%3A IRS Issues Guidance on Mid-Year Amendments to Certain Safe Harbor Plans