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Message Boards Digest

April 19, 2018

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

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BG5150 created a topic in 401(k) Plans

Excluding some NHCE from Safe Harbor Match

I have a client that has two people (NHCE) that they would like to exclude from the Basic Safe Harbor Match; they would still be able to defer. Coverage is not an issue. But, I still don't feel I can do this. But why not?
Number of replies posted  5 replies      Number of times viewed  109 views      Add Reply
 
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austin3515 created a topic in 401(k) Plans

Interesting Update On VCP Fees (not exciting news)

For those who are interested. https://www.napa-net.org/news/technical-competence/regulatory-agencies/irs-pressed-on-vcp-fee-changes-at-hill-hearing/?mqsc=E3950396
Number of replies posted  2 replies      Number of times viewed  62 views      Add Reply
Author's photo

WCC created a topic in 401(k) Plans

402g Roth failure correction after April 15

A participant contributed $15,000 Roth deferrals to plan A and $10,000 Roth deferrals to plan B. Participant is not catch up eligible and the plans are unrelated. Participant informed the plan sponsor today of the excess. My understanding is that the excess cannot returned after after April 15. However, the bundled recordkeeper (one of the large ones) says they will refund the excess anytime. This does not not seem right to me based on other threads (like the one below) but I cannot find specific authority for this stance. Is it just based on distributable event rules? Since neither plan fails 401(a)(30) can they return the excess after April 15? Can anyone provide authority for this? Thank you!! Edit: I finally found this in the EOB after I posted this question. 1.d. Are corrective distributions allowed after the April 15th deadline? The last sentence of IRC
Number of replies posted  8 replies      Number of times viewed  105 views      Add Reply
Author's photo

52626 created a topic in SEP, SARSEP and SIMPLE Plans

Acquired Company with SIMPLE IRA

I realize this topic was discussed in the past, but want to see if anything has changed. Company A has a SIMPLE IRA Company B has a 401(K) May 1, 2018 Company B purchases (stock purchase) Company A. Company B wants the employees of Company A to participant in the 401(k) Plan. The SIMPLE will remain in place ( "frozen") until it can be terminated. My initial thought was Company A employees cannot defer into the 401(k) Plan until 1/1/2019. Their contributions would continue to be made to the SIMPLE Plan for 2018. Company B would make the employer contribution. 1. Does Company B have to continue the SIMPLE Plan - could they leave the plan alone ( no contributions) until it can be terminated? 2. Is there any way the employees of company A can defer into the 401k plan for 2018? Or are they out of luck? thanks
Number of replies posted  0 replies      Number of times viewed  16 views      Add Reply
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