Message Boards Digest

September 10, 2018

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

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Fiduciary Guidance Counsel created a topic in Retirement Plans in General

Does an Insurance Company Check Whether Its Fidelity Bond Covers Someone Convicted of a Crime?

ERISA Section 411 makes it at least improper for someone convicted of any of a long list of crimes (if the conviction or the end of the imprisonment, whichever is later, is in the past 13 years) from serving in any almost any role regarding an employee-benefit plan. Does an insurance company, before issuing an ERISA Section 412 fidelity-bond insurance contract, do anything to check whether a person whose dishonest act the contract would insure lacks a disqualifying conviction? My intuition tells me that the size and probability of an insurer's potential liability on a typical fidelity bond is so small that an insurer doesn't bother checking anything. But I'd like to be wrong about that.
Number of replies posted  6 replies      Number of times viewed  60 views      Add Reply

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austin3515 created a topic in 401(k) Plans

Fee Disclosures for Plan Having Participant-Directed Accounts

Client wants to set up 3 pools of money: Conservative, Moderate and Aggressive. The underlying securities will be stocks and bonds. Has anyone figured out how to handle fee disclosures on this? Note that we will be doing quarterly valuations, and participants can choose to switch quarterly. And it's a small group, almost exclusively investment experts. They're not really worried about would happen if the market tanked kind of a thing. Maybe they should be, but they know their employees well. What I'm really interested in is the fee disclosure requirement.
Number of replies posted  4 replies      Number of times viewed  58 views      Add Reply
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msmith created a topic in Cross-Tested Plans

Using Imputed Disparity to Pass the General Test in a Sorta-Short Plan Year

Company started in July 2018. For a calendar year plan, we will have a 01/01/2018 effective date. Do we have to pro-rate the TWB if using imputed disparity to pass the general test?
Number of replies posted  2 replies      Number of times viewed  41 views      Add Reply
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M Norton created a topic in Correction of Plan Defects

Twenty-One Cents Still on the Table: De Minimis Exception to Form 5330 Filing Requirement?

Plan sponsor had late deposits of elective deferrals for multiple pay periods in 2017. Due date for Form 5500-SF and Form 5330 were extended by filing Form 5558; $19 was paid with extension for amount due on Form 5330. After preparing Form 5330, excise tax total is $19.21. Is it necessary to remit $0.21 with the form? Is there some kind of de minimis that would apply to this situation? Thanks.
Number of replies posted  1 reply      Number of times viewed  43 views      Add Reply
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bibliwho created a topic in Health Plans (Including ACA, COBRA, HIPAA)

Benefit Neutrality and Integrated HRA Plans

I've been tying myself in knots on the math trying to compare the cost-sharing implications of switching from a Cadillac health plan to a higher deductible plan with an integrated HRA. The former is a family plan with a standard deductible of $0, no coinsurance, and a max out-of-pocket of $3k/$6k (per person/per family). The latter has a standard deductible of $3k/$9k, no coinsurance, and a max out-of-pocket of $5k/$10k. Copays are naturally a bit higher, and the plan is obviously more restrictive all around. If one of the goals is to minimize cost-shifting to employees, how would you go about determining the appropriate HRA contribution amount? My current thinking is that this should be based simply on the increase in the max out-of-pocket i.e., $4k ($10k -- $6k). But I'm being thrown off by the much larger increase in exposure from the high deductible ($9k vs. $0). I understand that comparisons will vary depending on total medical expenses, the number of visits, procedures, etc., and should account for the employee's savings from lower premiums. So it's complex. Can someone help to clarify my thinking and perhaps add some insight on how best to approach this?
Number of replies posted  7 replies      Number of times viewed  49 views      Add Reply
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austin3515 created a topic in Form 5500

Code C on 8955-SSA

Code C Purpose: "Use this code for a participant previously reported under the plan of a different plan sponsor and who will now be receiving a future benefit from the plan reported on this form. Also complete columns (b), (c), (h), and (i)." So a client is merging Plan A into Plan B. Plan A happened to be an employee contribution only and Plan B happened to be Employer contributions only. Both are sponsored by the same plan sponsor. Based on the instructions above, I am planning on NOT reporting these folks as a Code C on the surviving plan. Do you agree?
Number of replies posted  5 replies      Number of times viewed  36 views      Add Reply
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coleboy created a topic in 401(k) Plans

Compensation for Computing Profit Sharing Allocation

Basic Admin 101 question. Plan compensation is based the participant's date of entering the plan. For the purposes of allocating a profit sharing contribution, does one use compensation during the entire plan year, or only compensation received after the participant entered the plan?
Number of replies posted  3 replies      Number of times viewed  35 views      Add Reply, Inc.
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