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Message Boards Digest

December 12, 2018

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

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cheersmate created a topic in 401(k) Plans

Crediting Service for Temp Agency

The employer occasionally uses the services of a temporary agency to find new talent. Occasionally after 90 days the "temp" is offered a permanent position with the employer. Does the employer have to count service while a "temp" for the plan's eligibility waiting period, vesting credits and accruals? In other words, does the employer have to bridge that service while working "temp" now that they are hired to a permanent position with the employer?
Number of replies posted  1 reply      Number of times viewed  29 views      Add Reply
 
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Pixie created a topic in 401(k) Plans

Business Owner Dies; OK to Make a Post-Death Profit Sharing Contribution?

One of our clients had an accidental death. Her business was real estate. Her husband can receive her post-death commissions for a time. Can a contribution be made for her, for the 2018 plan year?
Number of replies posted  2 replies      Number of times viewed  40 views      Add Reply
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Lou S. created a topic in Distributions and Loans, Other than QDROs

Terminating Plan - RMD Required?

A safe harbor 401(k) Plan will be terminating 12/31/2018. Two participants are over age 70-1/2 but are not 5% owners and have not separated from service. Are they required to receive a 2019 RMD from the plan if they are employed when the distribution is made in 2019? If they aren't required to take an RMD and they roll over 100% of their balance due to plan termination but later separate from service before 12/31/2019, is a retroactive RMD triggered for 2019?
Number of replies posted  2 replies      Number of times viewed  39 views      Add Reply
Author's photo

Fiduciary Guidance Counsel created a topic in Retirement Plans in General

Which U.S. Government Activities Stop During a Shutdown?

Which governmental activities stop (or continue) during a U.S. government shutdown? Here's the DOL plan, the IRS plan, and the contingency plans of other agencies.
Number of replies posted  1 reply      Number of times viewed  64 views      Add Reply
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TPA Bob created a topic in 401(k) Plans

415 Limits and Allocation to Other Participants

In our FIS Corbel document under Maximum Annual Additions, it provides in part that if an employer contribution otherwise would cause annual additions to exceed maximum permissible amounts, the contribution is reduced and any amount in excess of the maximum permissible amount that would have been allocated "may be allocated to other Participants." Our employer-customer's plan has only three participants, who are owners or related to owners (no other employees, all HCEs). Two out of three of the participants have maximized their 401(k) for the year. When we determine the 25% deductible employer contribution based on eligible compensation and we allocate based on plan formula, these two participants will hit their 415 limit. Which then, per the plan document, would be allocated to the other owner who did not defer. Any problems with allocating additional monies to this third participant once the first two participants have reached their 415 limit? I have been told this is aggressive but I can't find any guidance that says we cannot do this.
Number of replies posted  2 replies      Number of times viewed  40 views      Add Reply
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pjb1835 created a topic in 401(k) Plans

Roth Rollovers Allowed But Not Roth 401(k) Elective Deferrals?

Can a 401(k) plan allow for Roth rollover contributions but not Roth elective deferrals? If not, why not?
Number of replies posted  3 replies      Number of times viewed  36 views      Add Reply
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