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Message Boards Digest

April 17, 2019

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

Vlad401k created a topic in Distributions and Loans, Other than QDROs

ADP Failure; Dividing Corrective Distributions Between Traditional and Roth Sources

Let's say the plan failed ADP testing and a participant has both Roth and Traditional sources. If the plan document doesn't state the order in which the corrective distributions should be done, how would you process the corrective distributions? Would you process it proportionately from each source or would you start with Traditional source first and then do Roth source if the amount exceeds Traditional source?
Number of replies posted  2 replies      Number of times viewed  44 views      Add Reply
 
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David Peckham created a topic in Defined Benefit Plans, Including Cash Balance

Changing the Annual Payment Date for a DB Participant Taking RMDs in Annuity-Type Installments

Participant A is age 77. Has been taking annual RMDs for 7 years. In his first RMD year, he took out the RMD in December. Every year since then, we have advised taking his RMD in December and not any earlier, in order to satisfy the "generally consistent" annual annuity distribution that he would be receiving from an insurance company if his annual annuity came from such as source. Now he's pressing us to allow him to take his RMD earlier in the year. Can we make some sort of one-time adjustment to allow this? He would like to switch to taking his annual RMD on March 15 each year.
Number of replies posted  0 replies      Number of times viewed  36 views      Add Reply

Ajillity created a topic in Form 5500

DFVCP Questions for Small Plan: What Will the Public See?

Need to file 5500s back to 2002 for a small plan. Have a few questions. Will all the filings appear on EFAST2 for public viewing? If so, how should the Schedule P be handled since it requires a signature and will be attached as a PDF? Should it be treated as an SB an only have the fiduciary's initials?
Number of replies posted  1 reply      Number of times viewed  21 views      Add Reply

jireh87 created a topic in SEP, SARSEP and SIMPLE Plans

Notice of Benefits to Participants in SEP Arrangement

I have a client whose SEP arrangement recently was audited by the IRS resulting in corrective contributions to employees. As part of the closing agreement, the IRS wants the client to adopt a prototype SEP document and provide notice to employees of their benefits. Anyone know where I can find a sample notice letter? Just want to make sure I don't leave anything (important) out.
Number of replies posted  2 replies      Number of times viewed  37 views      Add Reply
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