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Message Boards Digest

December 5, 2017

Here are the most recently added topics on the BenefitsLink Message Boards:

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Trisports created a topic in Form 5500

Plan Received Late 5500 Notice from IRS; DFVCP Available?

The plan was merged into another plan and the 2015 final (short plan year) Form 5500 was not filed. The plan sponsor received a notice from the IRS inquiring about the filing. We are proposing DFVCP. Will the IRS notice preclude them from filing under DFVCP? I'm reading that you can file under DFVCP as long as you don't receive a notice from the DOL but there is no reference to IRS.
Number of replies posted  3 replies      Number of times viewed  50 views      Add Reply
 
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Patricia Neal Jensen created a topic in 403(b) Plans, Accounts or Annuities

Plan Filed a Form 5500 in 2016; Puts Non-ERISA Status at Risk?

Client has a Non-ERISA plan, and appears to meet all requirements to remain Non-ERISA. But I've learned that the client filed a Form 5500 for 2016. Does that filing jeopardize the plan's Non-ERISA status?
Number of replies posted  3 replies      Number of times viewed  38 views      Add Reply
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Mr Bagwell created a topic in 401(k) Plans

Catch Up Contributions for Non-Calendar Year Plan

Question about off-calendar plan year and catch up. Little different twist than the usual "how much?" question. Plan year end is 9/30/2017. HCE employee turns 50 in 2017. Employee is on track to defer $24,000 during calendar year 2017. The catch up money would be in the 10/1/2017 to 12/31/2017 time frame. I am calculating a cross tested contribution for the 9/30/2017 plan year end. The employee would not get the benefit of the $6,000 catch up at the plan year 2016 (9/30/2017 PYE) time frame, correct? Put another way, does the employee get the catch up benefit for 2017 at the 9/30/2018 plan year end?
Number of replies posted  4 replies      Number of times viewed  71 views      Add Reply
Author's photo

Belgarath created a topic in Retirement Plans in General

Rate Group Testing Situation; Husband and Wife HCEs

Plan uses rate group testing on an allocations basis. 2 HCE's. Wife makes all the money and wants to max out. (Cross testing doesn't work because owners are much younger than the four employees.) Husband takes a nominal salary, defers the max, but is excluded from all other employer contributions. Question: when performing the Average Benefits Percentage Test, do his deferrals get added back in? Common sense says no, but I'm having a brain cramp.
Number of replies posted  3 replies      Number of times viewed  34 views      Add Reply
Author's photo

Tom Poje created a topic in Retirement Plans in General

Electronic Filing Shuts Down Tomorrow, Until January 8

"Planned Outage: December 6, 2017 - January 8, 2018. FIRE Prod: This service will be unavailable from approximately 6 p.m. Eastern time on Wednesday, December 6, 2017, until approximately 8 a.m. Eastern time on Monday, January 8, 2018, due to planned maintenance. We apologize for any inconvenience." I guess you can click the box special extension and fill in the reason as "DUH! It's late because I couldn't file, because you shut the thing down for a month. I wasn't ready anyway, but now I have a good excuse and you can't do anything about it."
Number of replies posted  1 reply      Number of times viewed  29 views      Add Reply
Author's photo

Belgarath created a topic in Health Plans (Including ACA, COBRA, HIPAA)

Employer to Adopt HRA While Ex-Employee on COBRA Coverage

Employer sponsors a group health plan. Employee terminates in 2017, elects COBRA coverage. Employer considering a modification of health coverage effective 1/1/2018 -- increasing deductibles, out of pocket expenses, etc., for everyone. To somewhat mitigate these effects, employer would institute an HRA. Would the employer be required to offer COBRA coverage on the HRA to this participant for the remainder of the COBRA period established as of the original date of termination of employment? I looked at some of the regulations; it seems to me that (under a "common sense" approach and looking at 54.4980B-3) because the "similarly situated" employees receive the HRA coverage, COBRA participants with the same health coverage should be able to be covered under the HRA. But perhaps a more appropriate reference might be 54.4980B-5, Q-4(c).
Number of replies posted  1 reply      Number of times viewed  21 views      Add Reply
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jim241 created a topic in Defined Benefit Plans, Including Cash Balance

Employers Didn't Sign Participation Agreements; Use EPCRS?

I have a situation in which a church defined benefit pension plan has two participating employers that have been making contributions and adopted the plan without an official participation agreement. One plan has been in the plan since spring 2017; the other since the mid-80's. I believe SCP might be able to be used for the first issue, and VCP for the second. Any thoughts?
Number of replies posted  2 replies      Number of times viewed  26 views      Add Reply
Author's photo

Jim Chad created a topic in 401(k) Plans

Plan Doesn't Define 'Break in Service'

If document doesn't specify, what is the measuring year for "break in service"? Did not work 500 hours in what 12 month period? Plan year? Calendar year? Employment Anniversary year? The year the document says to use for Eligibility? The year the document says to use for vesting?
Number of replies posted  2 replies      Number of times viewed  26 views      Add Reply
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