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Message Boards Digest

April 4, 2019

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

WCC created a topic in 401(k) Plans

Safe Harbor Match -- Document Silent on Calculation Period

We took over the admin of a plan that uses a safe harbor enhanced match formula. However, the document does not state the calculation period for the safe harbor match formula. The SPD and safe harbor notice just say participants will receive a match of 100% of 4% of compensation. I asked the document provider to point to the calculation period and they provided the following sentence from the plan doc: The Employer may make ADP Test Safe Harbor Contributions at the same time as it contributes Elective Deferrals or at any other time as permitted by law and regulation. The document provider is adamant that the calculation period is not required to be in the safe harbor notice, SPD or adoption agreement. They say this language provides the most flexibility so the plan administrator can decide at any point if the calculation will be done per pay-period, quarter, annually. It is a pre-approved plan document. I have never seen a document silent on the safe harbor calculation period. Is this common?
Number of replies posted  5 replies      Number of times viewed  63 views      Add Reply
 
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AS TPA created a topic in 401(k) Plans

Using Safe Harbor Matching Contributions to Meet Top Heavy Minimums

I have a plan that is top heavy and is also making a safe harbor match and new comparability profit sharing contribution for 2018. All participants are receiving a safe harbor match contribution that is equal to at least 3% of their compensation, which counts towards satisfying the top heavy minimum contribution. I know that if a participant is only receiving a safe harbor matching contribution that they are not treated as "benefiting" for purposes of the gateway test. But if those safe harbor matching contributions are being used to satisfy the top heavy minimum contribution requirement, does that change how the safe harbor matching contributions are treated for gateway purposes?
Number of replies posted  9 replies      Number of times viewed  76 views      Add Reply

DPSRich created a topic in Distributions and Loans, Other than QDROs

Mandatory Withholding on QDROs That Are Not Rolled Over?

Is 20% mandatory withholding required on QDROs that are NOT rolled over into another qualified plan or an IRA?
Number of replies posted  1 reply      Number of times viewed  31 views      Add Reply

HarleyBabe created a topic in 401(k) Plans

Revenue Sharing Payments: What Are They?

Can someone tell me how to easily explain to a client what a revenue sharing payment is and how it's generated and paid to the TPA. We receive basis points on assets but I need to explain exactly how that affects the participant accounts.
Number of replies posted  4 replies      Number of times viewed  31 views      Add Reply

Dave401k created a topic in Retirement Plans in General

Submission in 'Worst Plan Ever' Category

I have a plan that could be one of the worse plans out there and now is interested in getting into compliance. [1] They did not notify employees of their right to participate. We did the QNEC calculations and they were deposited. What is reported on the 5330 and which line? [2] They have not deposited the full Top Heavy contribution in 5 years. What do I need to do? Which correction program should I use? [3] We went back until 2012 to correct late 401k deposits. I was not aware of the deposits being late because they appeared to be on time (not egregiously late, and they replied "no" to our late deposit question every year). All of the deposits were done and we went back and did the earnings calculation. Needless to say a 5330 was not filed for prior years. What should I suggest they do?
Number of replies posted  3 replies      Number of times viewed  41 views      Add Reply

ldr created a topic in 401(k) Plans

Timing of Deferrals for Self-Employed and Partners

Is it acceptable for salary deferrals to be funded well after the end of the plan year for self-employed individuals, i.e. sole proprietors? It's an ERISA plan, not a solo 401(k) plan.
Number of replies posted  10 replies      Number of times viewed  45 views      Add Reply
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