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Message Boards Digest

November 19, 2019

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

Jenny created a topic in Continuing Professional Education

Looking for Advice on Preparing for DC-3 Exam

"I just took the DC-3 exam and failed with a 6. I did the practice exams again and again, as well as the after chapter questions. However, I feel DC-3 exam is different than DC-1 and DC-2. After chapter questions and practice exams are not that help, the actual exam feels more like a different direction. Are there any other friends here preparing for this exam? or if you already passed it would you please give me some tips regarding preparation for the exam?"

Number of replies posted  0 replies      Number of times viewed  35 views      Add Reply
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austin3515 created a topic in 401(k) Plans

Can a 3(16) Administrator Sign Discretionary Amendments on Behalf of a Client?

"Can a 3(16) Administrator sign discretionary amendments on behalf of a client?"

Number of replies posted  5 replies      Number of times viewed  61 views      Add Reply

PFranckowiak created a topic in 401(k) Plans

ADP Testing: Changing from Prior Year to Current Year

"Prior year testing. Takeover plan. Plan excludes bonus. Failed 414(s) for year ending 12/31/18. They used Total Compensation for the ADP Test for 12/31/2018. [1] This year, do we run the ADP test using Total Compensation for HCEs because the number we have for the NHCEs from last year was Total Compensation? [2] What is the rule for changing from Prior Year to Current Year, i.e., can we change or is there a 5 year wait? ADP has been Prior Year for a long time. ACP has been Current Year and just changed to Prior Year last year."

Number of replies posted  1 reply      Number of times viewed  36 views      Add Reply

Sidney created a topic in 401(k) Plans

Overlap Between Auto Election Period and a Blackout Period

"There is an upcoming conversion to another 401(k) plan provider/trustee. There are quarterly auto-enrollments into the plan. A notice will go out shortly advising of the January 1st entry into the plan. This notice will be sent by the current plan provider. Because of the ACA provision, participants must have 30 days to make an election or they will be defaulted in at 3%. The switch to the new plan provider will occur on December 20. There will be a blackout period beginning December 15, ending January 15. There has been a sudden realization that the enrollment window has now shortened from December 1 to December 14. Participants will not have 30 days to make an election. Would it be prudent to amend the plan to provide for a one-time extension of enrollment into the plan until after January 15?"

Number of replies posted  2 replies      Number of times viewed  37 views      Add Reply

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

Must Show 403(b) Employee Contributions on Form 5500 Even If No Employer Contributions?

"I don't handle 403(b) plans, but it is my understanding that the financial data must be shown on the series 5500 filing if employee contributions are being made to the plan even if the employer is not contributing to the plan. Correct?"

Number of replies posted  0 replies      Number of times viewed  24 views      Add Reply

mlp0816 created a topic in SEP, SARSEP and SIMPLE Plans

Terminate a SIMPLE IRA After November 1 Without Notice?

"I have a client that is selling his medical practice (5/1/2020). The buyers do not want to maintain the existing Company SIMPLE IRA Plan. Can it be terminated even though the client did not give notice to the employees by 11/1/2019? Does the fact that he is selling his practice weigh in?"

Number of replies posted  5 replies      Number of times viewed  48 views      Add Reply

hunter001 created a topic in How to Use the Message Boards (a.k.a. Forums)

Entry Date Is First Day of Payroll Period; Which Pay Date to Use for Deferrals?

"If a plan uses first day of each payroll period as an entry, does the plan sponsor start withholding deferrals on the pay date associated with that payroll? What if there is an overlapping paycheck? Example: Employee enters plan 10/27 (first day of next payroll period) with a 11/15 paydate. Paycheck on 11/1 for 10/13 - 10/26 pay period."

Number of replies posted  1 reply      Number of times viewed  34 views      Add Reply

TPApril created a topic in 401(k) Plans

Move Accounts of Terminated Participants Into Separate (More Conservative) Fund?

"Plan has a pooled account. Would there be a concern with placing terminated participants into a separate pooled account that just contains, say, a money market fund?"

Number of replies posted  12 replies      Number of times viewed  76 views      Add Reply

Belgarath created a topic in Retirement Plans in General

408b-2 Disclosures: Are You Combining Into One Document?

"When we do our 408b-2 disclosures, we specify the amount/formula for any Revenue Sharing all in the one disclosure document. However, I believe it is acceptable under the regulations to have this in more than one document, as long as the required information/format is used. Just curious if folks out there generally combine all in one document, or use two or more. For example, a basic 408b-2 disclosure that has everything except the Revenue Sharing formula, and then referring to an attachment prepared/published by the mutual fund company that describes the specific Revenue Sharing amounts/formula/calculation?"

Number of replies posted  3 replies      Number of times viewed  33 views      Add Reply

Jakyasar created a topic in Distributions and Loans, Other than QDROs

RMD Already Taken for 2019 But Short Plan Year Being Created That Ends in 2019

"Current plan year-end is 9/30/2019. RMD has been taken for 2019, based on 9/30/2018 balance, per Treas. Reg. section 1.401(a)(9)-5 Q&A 3. Now amending the plan year to be a short year, from 10/1/2019 to 12/31/2019. Because a calendar 2019 RMD already has been taken, will there be a need for a further allocation requirement based on the 9/30/19 balance? If there is, what is the methodology?"

Number of replies posted  1 reply      Number of times viewed  24 views      Add Reply

Jakyasar created a topic in Retirement Plans in General

Short Plan Year Being Created -- Effect on Compensation

"Current plan year is from 12/1/18 to 11/30/19. Compensation is defined as calendar year ending within fiscal year. So for this plan year, it is 2018 W-2. Now switching the plan year to the calendar year, meaning a very short plan year that begins 12/1/2019 and ends 12/31/2019. I assume we'll need to use the full 2019 W-2 for the short plan year, so what pro rata calculation is needed?"

Number of replies posted  0 replies      Number of times viewed  15 views      Add Reply

Belgarath created a topic in Correction of Plan Defects

IRS VCP Submission Got a Fast Approval!

"Rather shocking. We were asked to clean up a non-compliant plan. Just submitted an uncomplicated VCP filing in mid-October for failure to timely adopt a PPA document. Received IRS Compliance Statement already! Because I'm always quick to bash the IRS for taking too long, I have to give them kudos for doing this one so fast! Never had one turn around in 4 weeks previously."

Number of replies posted  2 replies      Number of times viewed  22 views      Add Reply

Vlad401k created a topic in 401(k) Plans

Late Contributions for 3 Years in a Row

"We have a plan that has had late contributions every year for the past 3 years. I understand we can only rely on the VFCP correction method (and using the VFCP calculator) if late contributions happen at most in 2 of the last 3 years. Correct? If so, what happens if the plan used the VFCP method in the previous 2 years (2016 and 2017) and had late contributions again this past year (2018)? Should we use the plan earnings to calculate what the participants are due? What if the plan lost money in 2018?"

Number of replies posted  1 reply      Number of times viewed  25 views      Add Reply
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