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Message Boards Digest

January 24, 2018

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

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WCC created a topic in 401(k) Plans

Combination of Safe Harbor Match and Discretionary Match: ACP Test Satisfied?

A 401k plan is written with a safe harbor match formula of 100% on the first 4%. Plan allows discretionary match. Plan sponsor wants to fund an additional 2% discretionary match so employees who defer 6% get a 100% match. I see this as two separate formulas: [1] safe harbor match is 100% of the first 4% deferred [2] discretionary match is 0% of first 4% deferred, 100% of next 2% deferred Therefore, I believe they are subject to the ACP test because of IRC Section 401(m)(11)(B)(ii) where the rate of match cannot increase as deferrals increase. A large recordkeeper disagrees with me, saying this approach complies because the formulas are in a sense "aggregated" and the match is uniform (i.e., does not increase as the rate of deferrals increase). Do you believe this match formula indeed satisfies the ACP test?
Number of replies posted  2 replies      Number of times viewed  53 views      Add Reply
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Buckoosier created a topic in Relius Administration

Handling 'Otherwise Excludable Employees' with Relius Software

On a plan with a 1 year wait, with entry on the date of completion of the 1 year, Relius determines the otherwise excludable employees based upon the statutory entry date approach. How do I code Relius to use the plan's entry dates for determining otherwise excludable employees?
Number of replies posted  2 replies      Number of times viewed  42 views      Add Reply
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AdKu created a topic in 401(k) Plans

Amending Form 5500 in Connection to Audit Report -- Financial Statement Section Updated to Comply Standard for Fair Value

The 2016 Form 5500 including the Independent Account Audit Report was filed timely. The Independent Auditor who prepared the Audit Report contacted me and the client, and informed us that the DOL required him to make a change on the Audit Report to comply with the standard for Fair Value. And he did make DOL-requested change. Other than that, the auditor informed us that he didn't change any number or any opinion on the audit report. Is there any issue amending the 2016 Form 5500 in 2018 in connection with the change in the audit report? My office use Relius Government forms.
Number of replies posted  2 replies      Number of times viewed  36 views      Add Reply
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Scuba 401 created a topic in 401(k) Plans

Spinning Off to New Company Having New Plan; Use Trustee-to-Trustee Transfer?

I have some employees basically leaving and forming a new entity. We want to start a new plan and do a trustee-to-trustee transfer of their entire accounts to the new plan (as opposed to distributions/rollovers). Would this be considered a spin-off and be allowed? We do not have an asset sale.
Number of replies posted  2 replies      Number of times viewed  39 views      Add Reply
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austin3515 created a topic in 401(k) Plans

Explanation of 1099-R Codes for Roth Distributions?

Can anyone point me to a good write-up of what codes to use for Roth distributions. There are dozens of combinations and permutations (maybe I exaggerate). Qualified/nonqualified, rollover/non-rollover, Code 1,2,7 etc. For example I cannot find even in the instructions how to report a non-rollover qualified distribution. The instructions just don't say what to do. What I need is a chart that goes through the scenarios and I can pick the codes. Maybe I'm overthinking it and someone can set me straight.
Number of replies posted  8 replies      Number of times viewed  57 views      Add Reply
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pmacduff created a topic in Distributions and Loans, Other than QDROs

Form 1096/1099-R: OK to Use Signature Stamp?

Does anyone know if a signature stamp is acceptable on the 1096?
Number of replies posted  0 replies      Number of times viewed  23 views      Add Reply
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wifrbr created a topic in 401(k) Plans

Entry Date After Termination/Rehire Under 401(k) Plan

Service requirement is 1 year; monthly entry dates. Participant was hired 10/20/2008, then terminated 12/31/2009. Deferred $4,000 in 2009, but took money out in 2015. Rehired on 2/1/2017. Does the participant come back into the plan on 2/1/2017?
Number of replies posted  2 replies      Number of times viewed  55 views      Add Reply
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Kansas401k created a topic in Qualified Domestic Relations Orders (QDROs)

QDRO on Unvested Assets?

I have received a DRO for a participant who is only partially vested in a 401(k) plan. The DRO instructs that we value the vested and unvested portion of account as of a specific date in the past. And then if/as the Participant vests in the future, the Alternate Payee will receive a proportionate share of that vesting. If the Participant doesn't vest, the AP doesn't receive any further funds. I'm accustomed to qualifying the DRO and immediately segregating the assets, but I can't give the AP unvested assets and then allow the AP to attain them as the Participant vests -- I can't imagine trying to keep track and move half of the newly vested portion over each year as the Participant vests further. The risk of a recordkeeping error seems high. The participant won't pay out from the vested portion and the attorney says there are no other options. Help!
Number of replies posted  8 replies      Number of times viewed  68 views      Add Reply
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Alyssa C created a topic in Health Plans (Including ACA, COBRA, HIPAA)

H&W Plan Administration: Can We Inquire as to Gender of Employee and Dependents?

Is there any prohibition on the employer or a TPA asking for an employee's or their dependent's gender when enrolling them in group benefit plans similar to the prohibitions on asking for gender on job applications? I understand that one can't deny benefits because of gender.
Number of replies posted  1 reply      Number of times viewed  29 views      Add Reply
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BG5150 created a topic in 401(k) Plans

What Comp to Use for 25% Deduction Limit?

Top heavy plan has an owner and 2 new participants who entered on 7/1. I'm trying to run a maximum contribution scenario. Allocation is on comp during participation. Owner's comp is $110,000 NHCE1's comp is $28,000 during the full year but $14,000 while a participant. NHCE2's comp is $24,000 during the full year but $12,000 while a participant. What total amount of compensation do I use in applying my 25% ceiling? $162,000 or $136,000?
Number of replies posted  1 reply      Number of times viewed  29 views      Add Reply
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AlbanyConsultant created a topic in 401(k) Plans

Deferral Elections Weren't Applied to Bonuses

Client paid first bonus in a long time and forgot that bonuses are subject to the same deferral election as regular compensation, so no deferrals were withheld. What's the best fix? If this was in the same plan/tax year, I'd consider letting him 'make it up' on the next payroll, but I'm concerned that going past the year will be a problem. I was reading this nice article: http://www.consultrms.com/Resources/49/EPCRS/92/Update-to-EPCRS-for-Correcting-Missed-Deferrals -- and I was thinking that the option on the 3rd page of the chart applies, but no penalty other than earnings seems like a pretty light way to get out of this.
Number of replies posted  1 reply      Number of times viewed  22 views      Add Reply
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