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Message Boards Digest

July 26, 2019

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

Cynchbeast created a topic in Retirement Plans in General

Plan Terminated But Small Amount of Money Remains in Trust

Very unusual situation -- we have a plan that was terminating PYE 06/30/19. They moved money to checking account and paid everyone out. Then without consulting us, instead of closing the account they kept it open and put in an additional $250 to cover bank fees. They now have about $167 remaining. Whereas we had planned to file a final 5500 for PYE 06/30/19 showing the plan terminated, they actually have no participants and a small bank balance remaining. Technically, it seems we would have to have them clear out the account and file a final 5500 for PYE 06/30/20. Any suggestions as to how you would handle this?
Number of replies posted  8 replies      Number of times viewed  75 views      Add Reply
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BERPA created a topic in 401(k) Plans

Handling a Bloated Forfeiture Account

Plan sponsor (with high employee turnover) eliminated 401(k) plan's fixed matching contribution effective January 15, 2018 and, after payment of expenses, has over $6,000 in the forfeiture account. Document provides that match forfeitures be used to reduce match for the plan year in which they occur and to pay expenses. Sponsor will continue to pay expenses from the account, but it may take a few years. Does anyone think there would be an issue? It's not like the account accumulated over a period of several years. We're following the terms of the plan. Not sure what else we can do.
Number of replies posted  7 replies      Number of times viewed  78 views      Add Reply

austin3515 created a topic in 401(k) Plans

Using 2019-19 EPCRS for Retroactive Amendment of Definition of Compensation

Self correction by amendment. We meet all other requirements. The only "issue" -- it so happens there are predominantly HCEs. Taxable Fringe Benefits were taken into account when they should not have been. We want to amend retroactively to 2018 as the correction to include TFB. Is that a problem? There's nothing in the new "correction by amendment" that is problematic. It references section 6.02 for correction principles, but it seems I can check off all those boxes too (i.e., it is consistent with general principles).
Number of replies posted  10 replies      Number of times viewed  61 views      Add Reply

cerickson created a topic in 401(k) Plans

ASG vs. MEP -- What's the Difference (Besides All Three Letters)

I have a plan for a collection of medical practices (we'll call it ABC Medicine). There are 7 doctors, they all have equal ownership in the partnership (LLC). The plan document says they are NOT an ASG, and that they are a MEP. There are participation agreements completed for each doctor's practice. The doctors' practices don't have any employees. The employees are all employed under ABC Medicine. Since the beginning, we've tested this plan as if it is an ASG. and only recently did the plan document issue come up. Can you help me understand the difference between an ASG and an MEP? I believe this is an ASG, but I need to be able to explain this to the client. And what kind of VCP corrections will be required if it is an ASG?
Number of replies posted  3 replies      Number of times viewed  38 views      Add Reply

kpickering created a topic in 401(k) Plans

Removing Auto Enrollment Feature: How to Announce?

I have a 401k plan that wants to remove the automatic enrollment features. Does anyone have a sample notice they can share for announcing this to employees?
Number of replies posted  0 replies      Number of times viewed  15 views      Add Reply
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