One total account per each participant

A Takeover 401k Plan. The plan has  1) deferrals, 2) safe harbor, and 3) PS contributions. The deferrals and safe harbor are of course 100% immediate vesting. The PS contributions are 100%  immediate vesting as well, (they are used to offset the DB Plan and only the vested PS balance can be used to offset the DB). Each participant has one total balance at year end and each participant's balance is not allocated between the three money types (deferrals, safe harbor, and PS contributions). Hardship distributions are not allowed in this plan and in service distributions after retirement age are allowed for all three money types. Distributions are made after a terminated participant requests payment for all three money types. Question:  Since all three money types have 100% immediate vesting and all share the same specs listed above, is it ok, that each participant's balance is shown as one total balance and is not broken down per money type?  Thank you in advance for any insights on this matter.

You say that only PS balances are used to offset a DB plan, but say that you don't know that number since there is only a total balance.  Unless I'm misunderstanding something, that would appear to be an insurmountable problem.  How has the offset been calc'd in the past?  

Setting that aside (tough to set aside since it is so significant), as I think I noted recently in a similar thread, for other purposes - it doesn't matter until it matters.  And it is likely to matter sooner or later.  Pulling the offset issue back into play, IT MATTERS.

... and the plan sponsor should always want the ability to point at something, "See, this is how much you put in, and that is how much we put in." 

A fundamental rule in consulting (but often lacking in recordkeeping and/or TPAs) is: No employee benefit is worth much if it's not communicated properly.

On the disclosure issue you

50 minutes ago, Bird said:

You say that only PS balances are used to offset a DB plan, but say that you don't know that number since there is only a total balance.  Unless I'm misunderstanding something, that would appear to be an insurmountable problem.  How has the offset been calc'd in the past?  

Setting that aside (tough to set aside since it is so significant), as I think I noted recently in a similar thread, for other purposes - it doesn't matter until it matters.  And it is likely to matter sooner or later.  Pulling the offset issue back into play, IT MATTERS.

Bird, I may be misunderstanding SSRR's question. But, I think SSRR is saying that the PS account balances (taking into account the floor-offset) are quantified internally at the time participant account balance statements go out and are reflected in that one total number.  

3 hours ago, FORMER ESQ. said:

Bird, I may be misunderstanding SSRR's question. But, I think SSRR is saying that the PS account balances (taking into account the floor-offset) are quantified internally at the time participant account balance statements go out and are reflected in that one total number.

Shrug.  I don't see any room for interpretation or misunderstanding.  It may have been misstated; that's different from misunderstanding.  I don't know how they could be "qualified internally" and at the same time "...not allocated between the three money types."

9 minutes ago, Bird said:

Shrug.  I don't see any room for interpretation or misunderstanding.  It may have been misstated; that's different from misunderstanding.  I don't know how they could be "qualified internally" and at the same time "...not allocated between the three money types."

I said "quantified" which is different than "qualified".  The term "allocation" as being used by the OP seems to mean "allocation" for disclosure purposes to participants.  That is my interpretation. Otherwise, the OP does not make any sense.  

On ‎10‎/‎21‎/‎2020 at 4:15 PM, SSRRS said:

 Since all three money types have 100% immediate vesting and all share the same specs listed above, is it ok, that each participant's balance is shown as one total balance and is not broken down per money type?

Someone else had this same question just the other day. Money is money, the taxation won't be different assuming the plan does not permit in-service distributions, and once it is distributed and rolled to an IRA, all the distinctions will go away. But the employer is total unable to amend the plan, e.g. to allow hardships or in-service distributions, so there's a high likelihood it will come back to bite them at some point.

18 hours ago, FORMER ESQ. said:

I said "quantified" which is different than "qualified". 

My bad (typo); I understand.

18 hours ago, FORMER ESQ. said:

The term "allocation" as being used by the OP seems to mean "allocation" for disclosure purposes to participants.  That is my interpretation. Otherwise, the OP does not make any sense.  

Well certainly they are determining and presumably showing the allocation somehow.  The problem is the offset, presumably on account balance, is a complete unknown.

Is it the PS "balance" that offsets the DB plan, or the PS "contribution" for the year that offsets what needs to go into the DB?