Message Boards Digest

May 22, 2019

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

mjf06241972 created a topic in Retirement Plans in General

Plan Eligibility

If an employee works less than 1000 hours for the past 5 years and in 2019 they work over 1000 hours, when would they enter the plan? 1/1 or 7/1 - 1 year - Age 21 - Actual hours. Thanks.
Number of replies posted  2 replies      Number of times viewed  55 views      Add Reply

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Belgarath created a topic in 401(k) Plans

EPCRS - Revenue Procedure 2019--19

Another question on this. The corrective amendments to conform plan language to actual operation - I'm guessing that this will not override the normal timing requirements for advance notice in a safe harbor plan? Or, is it meant to allow self-correction n such a situation?
Number of replies posted  0 replies      Number of times viewed  26 views      Add Reply

AlbanyConsultant created a topic in Investment Issues (Including Self-Directed)

discriminatory to remove access to an investment?

Short version: we took over a pooled profit sharing plan a few years back... all pooled except for a few participants with life insurance. No one new has purchased policies (we've made the plan sponsor give each participant a form to sign off saying that they don't want to purchase a policy), and all those with policies have terminated and gotten paid out except the owner, so his is the only policy left. Can the plan be amended to no longer allow life insurance going forward without causing a nondiscrimination issue? Or are they doomed to be stuck in CYA-mode until the owner gives up his policy? Thanks.
Number of replies posted  0 replies      Number of times viewed  25 views      Add Reply

thepensionmaven created a topic in Defined Benefit Plans, Including Cash Balance

sole prop cash balance plan

This is a cash balance plan for a sole proprietor with employees. We completed the annual contribution calculation, client asking if contributions must be made in cash or he can transfer some personally owned securities into the plan as contribution. I'm leaning towards "no"; the doc makes no mention.
Number of replies posted  10 replies      Number of times viewed  85 views      Add Reply

RayRay created a topic in 401(k) Plans

Three strikes rule for ADP tests?

Hello! Long time lurker, first time poster. I'm still relatively new to the game but I've completed the requirements for my QKA and I know enough to know there's still a lot I don't know yet. We've taken over a plan and the plan contact informed a member of our admin team that their prior TPA had warned them of a penalty for the plan failing ADP testing for three consecutive years. I've not come across this in any of my studies so far, and I cannot find anything about it anywhere - not on ERISApedia, not on tag, google, IRS site, nothing. Now, I know that the layperson generally has no idea what we're talking about when we discuss ADP/ACP testing or coverage or anything else, so the likelihood of the client having misunderstood something that the prior TPA said is certainly present. But have any of you ever come across this? If so, could you point me in the right direction? Thanks!
Number of replies posted  5 replies      Number of times viewed  90 views      Add Reply

tpyle created a topic in 401(k) Plans

QNEC in testing

Hello all, Had a client that didn't start an employee's deferral on time back in 2018. Since the missed contributions cross two plan years, how are the QNEC, missed match, and earnings tracked in testing with the 2018 testing being completed already. The entire correction is being made in 2019. Also just wanted to clarify that the missed match goes in as match source and not a QMAC since it's corrective. Thanks!
Number of replies posted  2 replies      Number of times viewed  37 views      Add Reply, Inc.
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