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Message Boards Digest

August 22, 2019

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

KaJay created a topic in Retirement Plans in General

Employee Refusal to Allow Corrective Contribution to 403(b)?

I am working with a church that is in the midst of an EPCRS correction. One of the areas they are working to correct is failure to offer participation in the plan to all eligible employees. Per the written plan document, part-time employees must be offered participation. They are looking at needing to provide a 1.5% corrective contribution on behalf of these PT employees. The question the church has proposed is, "what if an employee refuses the corrective contribution?". Because they were never offered an opportunity, these part time employees are not enrolled. If refusal is not an option, and an employee is unwilling to complete an enrollment form, can the church just provide the plan with the basic enrollment information (name, ssn, dob, etc.) so the plan could open an account for the individual to accept the contribution on the employee's behalf? If refusal is an option, could the church simply receive a signed statement from the employee in order to justify not making a "full correction"?

Number of replies posted  3 replies      Number of times viewed  59 views      Add Reply
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ERISAGal created a topic in 401(k) Plans

Safe Harbor 401(k) and Required Top Heavy Test

Have a Safe Harbor 401k plan that allocates a Safe Harbor enhanced match formula (100% up to 4% deferred). They also allocate a non-elective profit sharing contribution based on integration/permitted disparity and the plan falls into the Top Heavy threshold. The plan has a 1000 hours of service and last day requirement for receiving an allocation of the additional profit sharing contribution. EX-Have a participant who is NOT eligible for the allocation of the profit sharing due to the service, but is receiving the Safe Harbor Match because they deferred. Would this participant also have to receive a Top Heavy minimum allocation or would their Safe Harbor Match satisfy that requirement?

Number of replies posted  5 replies      Number of times viewed  55 views      Add Reply

BKadmin created a topic in Retirement Plans in General

Educational Material for Industry Newbies

Qualified Pension and Profit-Sharing Plans by Pamela Perdue vs. 401(k) Answer Book by Empower? Any thoughts on either of these materials for people new to the industry? Please share any other recommendations you may have as well.

Number of replies posted  4 replies      Number of times viewed  62 views      Add Reply

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

Hard-Frozen One-Person Plan -- Automatically Passes Minimum Coverage?

Just took over a hard-frozen one-participant defined benefit plan, who received the 204(h) and amendment. Does the plan automatically pass minimum coverage? There will be no new employees ever entering.

Number of replies posted  9 replies      Number of times viewed  63 views      Add Reply
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