Message Boards Digest

July 22, 2019

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

Belgarath created a topic in Cafeteria Plans

Multiple Employer Plans

Can you have Multiple Employer Plans in the Section 125 plan arena, similar to qualified plans? In other words, could an Association (of some sort) sponsor their own plan, and have unrelated (and by that, I mean not part of a controlled group or ASG) member businesses adopt the plan as Participating Employers, and have all testing, administration, 5500's if required, etc., done separately for each business, but there is no "MEWA" where contributions, etc. are being pooled? I'd have said not - and any "unrelated" business would just adopt a plan on their own. But perhaps this is a normal and common arrangement?
Number of replies posted  7 replies      Number of times viewed  63 views      Add Reply

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cdavis25 created a topic in 401(k) Plans

414(s) compensation

A client excludes bonus from compensation for deferral only. They include it for SH and PS. They use full 415 comp for 410(b) and 401(a)(4) testing and are passing. The 414(s) comp test is failing when excluding bonus from deferrals. Am I correct that really isn't an issue as long as they pass the general test on full 415 comp?
Number of replies posted  5 replies      Number of times viewed  56 views      Add Reply

Jeff Young created a topic in 401(k) Plans

Controlled Group

Facts: Company A and Company B are members of a controlled group and they adopt one single 401K plan with profit sharing discretionary component. Can each company pass a separate resolution to fund a different profit sharing percentage each year. Company A 3% and Company B 0% or some other %?
Number of replies posted  2 replies      Number of times viewed  41 views      Add Reply

Purplemandinga created a topic in 401(k) Plans

Prevailing Wage Disproportionate QNEC Question

A plan with large amounts of prevailinge wage QNECs is failing ADP. Here is my question: 1.401(k)-2(6)(iv)(A) says the following: General rule. Qualified nonelective contributions cannot be taken into account for a plan year for an NHCE to the extent such contributions exceed the product of that NHCE's compensation and the greater of 5% or two times the plan's representative contribution rate. Any qualified nonelective contribution taken into account under an ACP test under
Number of replies posted  0 replies      Number of times viewed  31 views      Add Reply

austin3515 created a topic in 401(k) Plans

FBO Account Fee Disclosure

Does anyone have a sample participant fee disclosure for an FBO account option? Participants can xfer balances between the main recordkeeper and "external" FBO accounts (still part of the Plan). If you'd be willing to share I would appreciate it!
Number of replies posted  0 replies      Number of times viewed  32 views      Add Reply

NW529 created a topic in 401(k) Plans

Plan Termination and 415 Limit

A 401k plan is on a calendar year and ceases contributions in March. However, the effective date of the termination is in July. Which date is used to determine the prorated 415 limit? If the employer had already ceased contributions with the intention to terminate, but did not make the effective date until several months after, aren't they essentially increasing the contributions allowed by the prorated 415 limit? Any guidance is appreciated!
Number of replies posted  3 replies      Number of times viewed  65 views      Add Reply

CaliBen created a topic in Health Plans (Including ACA, COBRA, HIPAA)

PBM / Rx Forum / Message Board

Does anyone know of a site similar to BenefitsLink that solely focuses on PBMs and Rx plans?
Number of replies posted  0 replies      Number of times viewed  16 views      Add Reply

draper1 created a topic in Plan Terminations

vesting on plan termination

Generally, plan termination resolutions will state that plan participants become 100% vested on the plan termination date. If a termination is later rescinded by the plan sponsor or falls through due to say PBGC disapproval, is the 100% vesting locked in? Has anyone seen or used language in a plan termination resolution stating that should the plan revert to an "ongoing" plan status such 100% vesting will be inapplicable and the vesting schedule under Section x.x will apply?
Number of replies posted  0 replies      Number of times viewed  23 views      Add Reply, Inc.
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