Message Boards Digest

March 17, 2020

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

OR-ERISA created a topic in Correction of Plan Defects

Defined Contribution Overpayment Repayment Amount Calculation

"Looking for input regarding the calculation of the amount an employee is required to repay under Rev. Proc. 2019-19, Section 6.06(4)(a). The Overpayment amount is $100,000. Under Section 6.06(4), the repayment amount would be $100,000 adjusted for Earnings at the plan's earnings rate. In the current investment environment, the Plan has suffered significant losses. Is the demanded repayment amount $100,000 minus the losses at the plan's earnings rate up to the date of repayment (e.g, $96,500)? Or is the repayment amount merely $100,000 not adjusted for a loss (because there are simply no earnings)?"

1 reply   |    33 views   |    Add Reply

It's time to upgrade your Compliance Software!

Sponsored by Wolters Kluwer
Leery of transitioning? Our top-notch customer support team and intuitive software eases the transition. Robust features and competitively priced (upgrade doesn't mean pay more), our 100% web-based Compliance Module is worth exploring. Learn more.

TPApril created a topic in 401(k) Plans

Annual Pooled Account Statements (When Markets Have Changed)

"For old school plans that have all accounts in a pooled trust, no participants can make elections, and they get one annual statement. As we send these out, I'm curious if others are sending out statements as related to the current (and quite large) decrease in market value. As it is, we intend to communicate to clients that we recommend a 3-31-20 special allocation for new distributions, and we will need to communicate something to participants."

12 replies   |    105 views   |    Add Reply

AlbanyConsultant created a topic in Retirement Plans in General

Dental Layoffs Due to Coronavirus -- Maybe Rehiring?

"I know this is way early for this discussion, but here goes anyway... Just had a dentist call to say that he is following the ADA recommendation and basically shutting down for the next three weeks. Since his employees don't want to use their vacation days and prefer to collect unemployment, he is going to give them what they want and fire them (NY is waiving the usual one-week waiting period for unemployment benefits). He intends to rehire them all in about a month, but was concerned about what effect it might have on the plan. Obviously, they can't defer while they're not paid, and they don't have plan compensation during this period so their end-of-year safe harbor and profit sharing will end up being lower. For those normally working just over 1,000 hours per year (and if that's a requirement for a profit sharing allocation), they might fall below the threshold and it could cause a problem with 410(b) testing. And... what if he doesn't hire them all back?

I know partial plan termination is partially facts and circumstances, so maybe this could be argued, but I'm thinking this might come into play if he lets go 7 and rehires 4 because business is slow to restart.

According to this dentist, this is going to be a common situation for many small dental practices, so I figured I'd toss it out here so we can start discussing it."

4 replies   |    54 views   |    Add Reply

BG5150 created a topic in 401(k) Plans

Calculation of Section 415 Limit for Self-Employed Individual

"Sole Prop. Over age 50. Gross Sched C: $19,114. Net after SECA, etc: $17,764. Deferrals: $17,764. Section 415 limit: 100%. Can he put in another $6,000 as catch-up? Can he put in PS and have some of the $17,764 classified as catch-up? (I know the PS would lower the plan comp.) I'm having a hard time reconciling these numbers with 415 and the comp on Sched C."

0 replies   |    20 views   |    Add Reply

Here are the most recently posted jobs on, a service of BenefitsLink:

View job as Retirement Plan Administrator Retirement Plan Administrator  View details

Bates & Company
Winter Park FL

View job as Health Insurance Specialist (Program Policy) Health Insurance Specialist (Program Policy)  View details

Centers for Medicare & Medicaid Services [CMS]
Bethesda MD / Woodlawn MD / Telecommute

View job as Management and Program Analyst Management and Program Analyst  View details

Pension Benefit Guaranty Corporation [PBGC]
Washington DC / Telecommute

View job as DC Plan Administrator DC Plan Administrator  View details

Retirement, LLC
Oklahoma City OK / Sioux Falls SD / Telecommute

►View More Jobs

►Post a Job

►Get Instant Job Alerts, 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 2020, 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