Message Boards Digest

December 2, 2019

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

Molgilny89 created a topic in 401(k) Plans

Plans of Unrelated Employers Using Commingled Assets in a Single Trust?

"Can the assets of multiple unrelated 401k plans be commingled into one single trust in order to benefit from cheaper costs through economies of scale? I know the DOL has stated that there is nothing in ERISA to prevent this for multiple plans sponsored by employers under common control but it's unclear whether that would apply to unrelated employers as well."

Number of replies posted  2 replies      Number of times viewed  56 views      Add Reply

ASC CE Webcast: Ethics for Employee Benefit Practitioners

Sponsored by ASC
Our annual ethics webcast is here! Topics include an overview of ethical responsibilities, significant ethical concerns of the IRS Office of Professional Responsibility, new practical case studies and much more. Register Now!

BG5150 created a topic in 401(k) Plans

Can create a 2020 SHS plan early December

"I know of the 30-days rule for providing notices. But what if someone decides in December to start a SH 401(k) plan? Can they not do it? What if it's the first week or two of the month? Wouldn't that be like an "as soon as administratively feasible" situation?"
Number of replies posted  4 replies      Number of times viewed  75 views      Add Reply

Socal.actuary created a topic in Defined Benefit Plans, Including Cash Balance

401(a)(26) issue

"We have a defined benefit plan, covering only a Key employee, and then in 2016, 3 other employees joined the plan and accrued at least a 0.5% accrual. The plan was frozen 12/31/2016. No other employees. The question I am dealing with whether I am satisfying 401(a)(26) for this frozen plan since 2016 as there are no accruals as the plan is a hard freeze. Since there are 6 "participants", am I satisfying 401(a)(26) since 2016? I find the reg hard to follow for db plan subject to a hard freeze."
Number of replies posted  1 reply      Number of times viewed  32 views      Add Reply

Socal.actuary created a topic in Defined Benefit Plans, Including Cash Balance

Satisfying 401(a)(26) in an Offset Situation (Two DB Plans)

"The client had a DB plan for many years, which became very overfunded. A new DB plan was created, with the idea of a carve-out or offset between the plans. Plan A covers 2 participants and provides a benefit of 6% x service accrual. Plan B provides a benefit of 8% x participation. In Years 1 and 2, the benefit accrued in Plan A is fully offset by the Plan B accrual. Question is, how to satisfy 401(a)(26) for Plan A for these years? From what I have studied, 401(a)(26) might not be satisfied until both plans can be aggregated for 401(a)(26)."

Number of replies posted  0 replies      Number of times viewed  33 views      Add Reply

austin3515 created a topic in 457 Plans

Non-Corporate Trustee of a Rabbi Trust?

"The model Rabbi Trust from the IRS seems to limit trustees to the following: 'a bank trust department or other party that may be granted corporate trustee powers under state law.' Does this preclude an individual from service as trustee of a Rabbi Trust? I would not think so, but I note they use the terms 'granted CORPORATE trustee powers...' Also, do you agree that an individual cannot serve as the trustee of his own account because to so he would have constructive receipt of the funds?"

Number of replies posted  2 replies      Number of times viewed  30 views      Add Reply, Inc.
1298 Minnesota Avenue, Suite H
Winter Park, Florida 32789
(407) 644-4146

Lois Baker, J.D., President
David Rhett Baker, J.D., Editor and Publisher
Holly Horton, Business Manager

Copyright 2019, Inc. All materials contained in this mailing are protected by United States copyright law and may not be reproduced, distributed, transmitted, displayed, published or broadcast without the prior written permission of, Inc., or in the case of third party materials, the owner of those materials. You may not alter or remove any trademark, copyright or other notices from copies of the content.

Links to web sites other than and are offered as a service to our readers; we were not involved in their production and are not responsible for their content.

Unsubscribe | Privacy Policy