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Message Boards Digest

March 23, 2018

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

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Young Curmudgeon created a topic in 401(k) Plans

Controlled Group Transition Rule Applicablity

I am getting conflicting answers as to whether the transition rule for acquisition solely applies to 410(b) or whether we can apply it to 401(a)(4) testing also. Situation: Company B becomes a controlled group with Company A due to ownership change on 4/1/18. Company A and Company B each sponsor 401k plans with calendar plan years. A's is a cross tested Safe Harbor 401k, B's is a cross tested non-Safe Harbor 401k. Do we need to combine them for testing 401(a)(4) for 2018 and 2019? What about ADP testing, because B is not a Safe Harbor 401k?
Number of replies posted  0 replies      Number of times viewed  22 views      Add Reply
 
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AlbanyConsultant created a topic in Plan Terminations

Plan Is Terminating, Not the Participant: RMD Needed?

71+ year old non-owner participant is not taking RMDs because she's still employed. The plan is terminating in 2018, but not due to the business closing, so the participant will continue to be employed. Does she need to take a 2018 RMD before she can roll over the remainder of her distribution?
Number of replies posted  3 replies      Number of times viewed  51 views      Add Reply
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MAS created a topic in Plan Terminations

ESOP Plan Termination; When Does Form 5500 Filing Requirement End?

An ESOP Plan is terminating. All assets have been distributed except for the accounts of the owners, who have chosen to take their distribution in installments over 5 years. The Plan will need to file a Form 5500 each year until the assets are zero (I think), but the attorney disagrees. Who's right?
Number of replies posted  3 replies      Number of times viewed  44 views      Add Reply
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MarkGAllen created a topic in 401(k) Plans

Former Employer Holding My 401(k) Account Hostage

First let me say I am not a benefits manager, I am in operations. I left my employer in March of 2017. The company has well over 1,000 employees and has locations in 3 states. When I started my with my new employer, I attempted to roll over my previous 401k. The administrator replied that my 401K would not be available for me to roll over -- or do anything with the account outside of the plan -- until Dec. 31, 2018. Why would that be?
Number of replies posted  15 replies      Number of times viewed  96 views      Add Reply
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Flyboyjohn created a topic in Health Plans (Including ACA, COBRA, HIPAA)

'Affordable' Coverage Offered But Employee Still Qualifies for Subsidy on Marketplace?

Are there circumstances where the employer offers affordable, minimum value health coverage but the employee can still qualify for a marketplace subsidy (the premium tax credit)? Stated differently, is the definition of what's affordable for purposes of the employer mandate exactly the same as the definition used for purposes of PTC qualification? We've encountered situations where subsidies have been awarded despite our submission of proof that the employee declined an offer of coverage that met an affordability safe harbor.
Number of replies posted  1 reply      Number of times viewed  16 views      Add Reply
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pholosofizer created a topic in 401(k) Plans

More ADP Refunds Due to Discovery of Wrong Compensation Figures?

What should we do if a plan previously corrected a failed ADP test timely but now, several years later, informs us that compensation was incorrect and that, after re-running, the refunds should have been even higher? Would this be considered a late correction (after 12 months ... and would we have to go through VCP)? Or could we simply just have extra corrections processed for the affected participants still in the plan and perhaps inform the ones that have left that they might have ineligible money sitting in whatever account they moved to? I know if the refund amounts that came out were too high to begin with, we make an effort to have the money returned to the plan.
Number of replies posted  1 reply      Number of times viewed  25 views      Add Reply
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Loves401(k) created a topic in ERPA (Enrolled Retirement Plan Agent)

Seeking Low-Cost Continuing Education for ERPAs

What have people found -- besides SunGard and ASPPA conferences -- for CE credit as an ERPA?
Number of replies posted  3 replies      Number of times viewed  15 views      Add Reply
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