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Message Boards Digest

December 19, 2017

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

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PFranckowiak created a topic in Distributions and Loans, Other than QDROs

Take Out Roth Component Only (as In-Service Distribution)?

Participant wants an in-service distribution. Has traditional 401k, match and Roth. Can he take just his Roth out in as an in-service distribution? He's an HCE.
Number of replies posted  3 replies      Number of times viewed  56 views      Add Reply
 
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waid10 created a topic in Plan Terminations

DB Terminated; Assets Distributed; Oops, Here's Another Account

We terminated our pension plan, and distributed all assets. Somehow we missed a plan participant, who is owed money. How to handle? There are no plan assets remaining, but the owed distribution amount is something we could cover from our corporate operating account. But how to process it? Should we distribute into an IRA for the participant? Also, I am guessing that we need to alert the PGGC.
Number of replies posted  0 replies      Number of times viewed  26 views      Add Reply
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PFranckowiak created a topic in Relius Administration

Plan Takeover Loan Setup

Plan Merger. Don't have money yet, cannot set up a takeover loan until money is transferred in. Participants already are having loan payments that we have just sitting in the account to set up the loan. Participant will not have much money when transferred in, because the participant apparently took a hardship distribution after the loan. If the balance isn't big enough, how do you force the loan to work? Software vendor says I need to put fake money in fake accounts. This is a large, audited daily plan, so I don't want to have "fake" accounts.
Number of replies posted  2 replies      Number of times viewed  35 views      Add Reply
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ldr created a topic in 401(k) Plans

Timing of Tuition Bills for Purposes of Hardship Withdrawal Eligibility

TPA and client agree that withdrawals for tuition under hardship provisions must be for upcoming, unpaid tuition. Client is worried that if a student begins a semester, let's say, September 1 and starts attending classes, but the tuition bill isn't issued, mailed and due until, say, October 1, then the tuition is "old" business and may not qualify, or at least might need to be somehow pro-rated such that the September expenses are not included. TPA takes the position that the timing of the billing does not matter; the bill is for the whole semester and the fact that it didn't have to be paid to the penny up front is immaterial. We can't find a chapter and verse anywhere that addresses the exact timing of the bill. What say you?
Number of replies posted  6 replies      Number of times viewed  67 views      Add Reply
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jane murray created a topic in Defined Benefit Plans, Including Cash Balance

New Plan; Application of 133-1/3 Percent Accrual Rule

Sole proprietor (age [55] considering to adopt a new defined benefit plan effective 1/1/2017. Does not have employees. Plan uses a unit benefit formula equal to 10% of average compensation times years of service. Sole proprietor has 10-plus years of past service and his average compensation is at the annual compensation limit. Normal Retirement Age is 65. Therefore, the accrued benefit as of 1/1/2017 is $1,791.67 (1/10 of the 2017 dollar limit) and the accrued benefit as of 12/31/2017 is the same $1,791.67. There's no target normal cost for 2017 and a funding target as of 1/1/2017. Accrued benefit as of 12/31/2018 will be $3,666.67 (2/10 of the 2018 dollar limit). Does the plan violate the 133-1/3 accrual rule for 2018 because the increase in the accrued benefit for 2018 ($3,666.67 less $1,791.67) is 133-1/3 percent more than the increase in the accrued benefit for 2017 ($1,791.67 less $1,791.67)? if the plan violates the 133-1/3 accrual rule, how can the plan be designed and still grant past service?
Number of replies posted  6 replies      Number of times viewed  50 views      Add Reply
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Jim Chad created a topic in Defined Benefit Plans, Including Cash Balance

Takeover Plan Has Only a Few Past SSA's

FreeERISA cannot provide SSA's anymore. If the employer doesn't have them, is there any other source for this information?
Number of replies posted  5 replies      Number of times viewed  36 views      Add Reply
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30Rock created a topic in 401(k) Plans

Write a Check Today for Military Leave Make-Up Contributions?

Do employee military leave make-up contributions have to be made on prospective W-2 pay, or can the employee write a check to the 401(k) account? For example, it's Decemeber 19 today, and the employee wants to contribute $18,000 for 2016 and $18,000 for 2017. She will have 2017 W-2 income after returning from military service. Does the $36,000 contribution need to be made from her remaining 2017 payroll, or can she write a check?
Number of replies posted  0 replies      Number of times viewed  16 views      Add Reply
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Fiduciary Guidance Counsel created a topic in Retirement Plans in General

How Will Tax Reform Affect Formation of Retirement Plans by Small Businesses?

What do you think about how Congress's H.R. 1, including its changes about how a business's income passes through to owners, how will this affect small-business employers' desire and willingness to create retirement plans?
Number of replies posted  2 replies      Number of times viewed  41 views      Add Reply
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John Feldt ERPA CPC QPA created a topic in 457 Plans

Length of Service Award Plans (LOSAPs)

Starting in 2018, the tax reform bill (if it passes) doubles the $3,000 limit per year to $6,000 per year for a plan to benefit certain volunteers (e.g. volunteer firefighters, fire prevention, EMS, ambulance). I am looking for a language in a plan document for a length-of-service-award plan. Also looking for anyone interested in writing an article for publication regarding this topic.
Number of replies posted  0 replies      Number of times viewed  8 views      Add Reply
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