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August 27, 2018

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

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kellygray79 created a topic in Computers and Other Technology

Having Trouble Getting Relius and Crystal Reports to Create Custom RMD Report

We're trying to create a custom RMD report that will list Participant, SSN, DOB, DOT, 5% Owner (Y/N) and Account Balance. I'm using one of the 70-1/2 Detail reports and I've added the fields for DOT and 5% Owner. I've inserted a sub-report to pull in the ending account balance, HOWEVER, it is pulling in information that is not in Relius. In my subtotal there are funds reporting a balance that have NO balance. It is including the correct balance for the funds that do have a balance, but I have NO idea where the other numbers are coming from!!! Is this possibly a database issue or a subreport linking issue? I don't have to use the subreport if any has suggestions for getting my ending balance onto the report. I am a novice (which is generous) but nothing I've tried is working -- with or without the subreport.
Number of replies posted  2 replies      Number of times viewed  44 views      Add Reply
 
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Dougsbpc created a topic in Defined Benefit Plans, Including Cash Balance

Another RMD Needed in Year of Plan Termination?

Suppose a greater than 5% owner has been taking annual payments of his RMD on 4/1 of each year. His most recent "RMD annuity payment" from the plan was 4/1/2018. Suppose the plan terminated 8/1/2018 and his benefit is distributed 9/15/2018. Is he required to take another RMD upon distribution even though his next installment is not until 4/1/2019?
Number of replies posted  3 replies      Number of times viewed  41 views      Add Reply
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RWPHoenix created a topic in 403(b) Plans, Accounts or Annuities

Grandfathered Non-ERISA 403(b) Plans -- How to Terminate?

A tax-exempt client just acquired another tax exempt that appears to have 3 different 403(b) arrangements with 3 different vendors. Two of these arrangements have 1 to 3 participants each; individual annuity contracts are involved. The arrangements were frozen before 2004 and are non-ERISA plans. It appears likely that plan documents were not required for these arrangements as of 12-31-2009. How does the client terminate these arrangements, because there is no plan to terminate? If the annuity contracts are between the employees/former employees and the contract issuers does my client need to do anything with respect to these arrangements? The contract issuers are saying that the employer needs to take no action; are the correct? The last arrangement had employee contributions made to it after 2005 and involves custodial accounts. There is no plan document (although there may be a custodial account application form) and I'm thinking a VCP is necessary to create a plan document retro to 2009. Am I off-base here? The mutual fund company holding the custodial accounts doesn't maintain a pre-approved 403(b) plan and generally has been of no assistance.
Number of replies posted  0 replies      Number of times viewed  38 views      Add Reply
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Bumppo23 created a topic in Plan Terminations

Wave of Involuntary Severance Correlates to a Particular Quarter of the Plan Year; Do Those Who Were Terminated in Other Quarters Also Get Full Vesting?

Hypothetical scenario. Employer sponsors a plan. Employment terminations occur as follows, in a given plan year:
Month 11 employee
Month 23 employees
Month 51 employee
Month 6-8 Inapplicable; all employees remain employed if employed on the last day of Month 5
Month 9:147 employees
Months 10 through 12:3 employees overall, in contrast to each month; whether one terminated each month, one refrains from imparting
I use the terms Month 5 and so forth to accommodate plan years other than calendar years. The wave of employees severed from employment during Month 9 served as the only impetus to declare a partial termination. The earlier and subsequent severances, added together would occur as less than sufficient to declare a partial termination. Employees severed during Months 9-12 receive full vesting. Employees severed in the earlier months of the same plan year lack this granted full vesting. Prima facie, this administration occurs as unhelpful, as the applicable period serves as the reckoning for the partial termination; correlation to a particular calendar quarter seems an aberration.
Number of replies posted  1 reply      Number of times viewed  51 views      Add Reply
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Sheila Mitchell created a topic in 401(k) Plans

Am I Entitled to My Ex-Husband's 401(k) upon His Death?

My ex-husband and I were married for 17 years. He worked at his job for 22 years and was employed at his death. He never remarried. He had 1 daughter. I'm sure she was named as the beneficiary of everything. Am I able to draw upon his 401k? Can someone please help me or give me information on where to start? I live in Florida.
Number of replies posted  1 reply      Number of times viewed  61 views      Add Reply
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ERISAAPPLE created a topic in Defined Benefit Plans, Including Cash Balance

Early Retirement Subsidy Created When Cash Balance Plan is Amended?

If a plan with an NRA of age 65 is amended to allow a fully vested participant to take at 62 in-service withdrawals of the participant's "full accrued benefit," according to informal guidance from the IRS, that could create an early retirement subsidy. The reason is the participant would receive, at least under the terms of the plan, the same pension without reduction for early commencement that the participant would receive at age 65. Does this same analysis apply for the modern cash balance plans? I know the prior guidance said the interest credits up to the NRA were part of the participant's "accrued benefit" (or interest credits up to distribution, if taken out earlier). Some say that at any given time the "accrued benefit" of a CB plan is the hypothetical account balance at that time. I'm not sure how all this works together in a CB plan post-PPA. Would a plan amendment that allows participants at age 62 to take their vested hypothetical account balance in-service create an early retirement subsidy?
Number of replies posted  2 replies      Number of times viewed  31 views      Add Reply
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Hojo created a topic in Defined Benefit Plans, Including Cash Balance

Termination of DB Plan Holding Employee Contributions

I have a plan that is terminating that also requires employee contributions. As we know, employee contributions are always 100% vested and upon plan termination all benefits are 100% vested. The total benefit for the plan is 2% of average comp (which includes the employee contributions). Assuming 5 year cliff vesting, I have a participant who terminated in 2008 with 2 years of service who had made employee contributions. Upon plan termination in 2018, the employee contributions remained in the plan. Do we have to restore the 2 years of service accrued benefit to pay out upon termination or do we assume that the nonvested portion was paid out since we have a BIS?
Number of replies posted  3 replies      Number of times viewed  24 views      Add Reply
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