Message Boards Digest

October 18, 2019

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

Miner88 created a topic in 403(b) Plans, Accounts or Annuities

Correcting Missed Elective Deferrals for Terminated Participants

A 403(b) plan incorrectly excluded some employees from participating in the plan over several years. To correct the error under VCP, a contribution must be made for the missed deferrals and the missed matching contributions. How are those corrective contributions made when the employees no longer participate in the plan (and don't have accounts anymore)?
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TommyGunn13 created a topic in 401(k) Plans

Calendar Year Match True Up, Non-Calendar Year Plan

Starting in 2018 the plan instituted a required match on a payroll basis with a true up contribution to be funded each year. This matching true up computation period is on a calendar year basis. The plan is an non-calendar year plan with a PYE of 9/30. The match true up was calculated based on the 2018 calendar year and the computation period crossed over two different plan years and was funded during PYE 9/30/2019. We are pulling year end census data including matching contribution data for plan year end testing and were questioning how to best include the match true up for testing. Is it appropriate to include it as a contribution made in the PYE 9/30/2019 even though the computation period was over parts of two separate plan years?

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Carike created a topic in 403(b) Plans, Accounts or Annuities

403(b) Hardship Distribution Made But No Suspension of Deferrals

A client issued a hardship distribution but payroll failed to suspend their contributions for 6 months. They have not (yet) adopted the amendment to dispense with this requirement and have issued other hardships where the contributions were suspended appropriately. What is the recommended remedy/correction for the Plan Sponsor in this situation?

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rocknrolls2 created a topic in Correction of Plan Defects

Supplementing a VCP Filing

I submitted a VCP filing on behalf of a client. After submitting the filing, it was determined that some of the corrective contributions indicated on the charts will have to be revised due to incorrect data. We have completed the revised charts and want to submit them to the IRS to become part of the filing. Two issues: [1] We have not even received an acknowledgement from the IRS. Should we send it anyway and ask them to replace portions of the existing material that was filed with the new material? Or should we wait until the IRS actually acknowledges our filing or has an agent send us a letter? What if the IRS approves the filing without any further action or change required on our part? [2] We submitted the filing in February 2019, before the new procedure for faxing the filing became effective. If we supplement the filing, can we send the supplemental filing and its attachments via regular mail or should we utilize the new procedure of faxing it to the Service?

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