Message Boards Digest

March 30, 2020

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

Ballangen created a topic in 401(k) Plans

Can My Company Force an Interim Valuation of My December 31, 2019 Account Balance?

"My former employer has a pooled 401k account which issues an annual statement in early Spring. I retired at end of last year and had planned to rollover my money into an IRA in January but discovered that I could not request a distribution until the annual statements were issued. By the time I was allowed to request the distribution the market had tanked and my request was denied. Now I'm told that the company will be doing an interim valuation for all participant accounts including mine. Is this legit?"

2 replies   |    61 views   |    Add Reply

Peter Gulia created a topic in Retirement Plans in General

Does It Matter That a Coronavirus Loan Gets No Relief from the Prohibited Transaction Exemption's Adequate-Security Condition?

"CARES Act Section 2202(b) revises or relieves Internal Revenue Code of 1986 Section 72(p) to allow a participant loan up to 100% (instead of 50%) of a vested account. But I see nothing that relaxes the conditions of a prohibited-transaction exemption under ERISA Section 408(b)(1) or IRC Section 4975(d)(1). Both those exemptions require that a loan be 'adequately secured'. The Labor department's rule (which governs for IRC Section 4975 too) requires adequate security and provides '[n]o more than 50% of the present value of a participant's vested accrued benefit may be considered by a plan as security for the outstanding balance of all plan loans made to that participant[.]' 29 C.F.R. Section 2550.408b-1(f)(2)(i). What should a practitioner say about whether to apply or ignore that 50% condition to a participant's claim for a loan that otherwise would be proper?"

2 replies   |    73 views   |    Add Reply

Belgarath created a topic in Form 5500

Plan Administrator Signed 5500 Form Electronically

"Hard as this is to believe, this is the first time this has happened. Instead of 'manually' signing it for us to file, the 'manual' signature on the form is an electronic image of the manual signature. I don't think this is any problem, yet I'm uncertain, and I wasn't quickly finding any guidance/FAQs that address this squarely."

2 replies   |    57 views   |    Add Reply

Mark Whitelaw created a topic in 409A Issues

409A and Best Interest Disclosure

"Just curious if anyone has seen anything dealing with participant enrollment disclosure and the possible implications of different best interest regulations."

0 replies   |    29 views   |    Add Reply

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

204(h) Notice When Plan is Frozen

"A plan freeze effective date is 3/15/2020. In my case the 204(h) notice date was January 31, 2020 with the following information: "Effective for the Plan Year Beginning January 1, 2020, our company Defined Benefit Pension Plan will be amended to freeze Benefit Accruals. All prior accured benefits are not affected, and all actuarial valuation methods are the same." Because the participants haven’t accrued anything for 2020 yet, I believe the accrued benefit is based on 1/1/2020. If you disagree with me, how would you put it in the 204(h) notice?"

1 reply   |    42 views   |    Add Reply

Ian created a topic in 401(k) Plans

CARES Act In-Service Distributions

"Does section 2202 of the CARES Act introduce a brand new in-service distribution category for 2020 coronavirus-related distributions by 'qualifying individuals'? Or does it still require employees to satisfy the existing IRS hardship safe harbors and then provide tax relief to hardship withdrawals that qualify as coronavirus-related distributions?"

11 replies   |    148 views   |    Add Reply

mjf06241972 created a topic in IRAs and Roth IRAs

IRA Conversion to Roth IRA

"If someone wants to do an IRA Conversion to Roth IRA, does that mean the taxes are paid at time of conversion for the IRA? What federal taxes are withheld, and would normal withholding of state income taxes apply?"

1 reply   |    29 views   |    Add Reply

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

PPA Restatement for DB Plans

"Has the deadline been extended for PPA Restatement of DB plans?"

1 reply   |    51 views   |    Add Reply

Jakyasar created a topic in Form 5500

Deadline to File 5500 Forms?

"I have a plan that has 4/15/2020 as its extended 5500/PBGC/SSA filing due date. So far there has been no grant of an extension, correct?"

6 replies   |    72 views   |    Add Reply

TPApril created a topic in Operating a TPA or Consulting Firm

Business Continuity Plans for Smaller TPA Firms

"I'm curious as to what other smaller TPA firms (less than five employees) have set up for business continuity plans. Customers are starting to ask."

2 replies   |    60 views   |    Add Reply

5500Nerd created a topic in Form 5500

Extension of Form 5500 Filing Deadline Due to COVID-19?

"I have been monitoring both the IRS and DOL/EBSA websites to see if any special extensions will be given towards the Form 5500s. I realize that this not a natural disaster such as hurricane; nevertheless our situation with COVID-19 has brought many businesses to a complete stop. Has there been any hint of a special extension?"

2 replies   |    39 views   |    Add Reply

susieQ created a topic in Operating a TPA or Consulting Firm

Are TPA Firms 'Essential' Businesses?

"Many cities have issued 'shelter-in-place' orders for citizens, closing businesses that are not considered essential. We are having a hard time determining if our TPA firm meets the Homeland Security definition of essential. We are purely administration, we are not a CPA firm, do not sell product."

11 replies   |    71 views   |    Add Reply

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

View job as Benefits/COBRA Specialist Benefits/COBRA Specialist  View details

Champaign IL

View job as Defined Benefit Consultant Defined Benefit Consultant  View details


View job as Healthcare Actuarial Analyst Healthcare Actuarial Analyst  View details

San Diego CA

View job as Healthcare Actuary Healthcare Actuary  View details

Indianapolis IN / Atlanta GA / Deerfield IL / Telecommute

View job as 401(k) Plan Administrator 401(k) Plan Administrator  View details

CA / MO / 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