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Message Boards Digest

April 6, 2020

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

austin3515 created a topic in 401(k) Plans

Discretionary Match Discontinuance

"Are people recommending a board resolution to discontinue a discretionary pay-period match? How about to start a discretionary pay-period match? I have always done it, and there is a bit of a disagreement in the office of how important it is."
5 replies   |    75 views   |    Add Reply

jmartinrps created a topic in 401(k) Plans

Changing plan year - too late?

"Have a profit sharing only plan with a current plan year end of 6/30/20. They have talked about changing to a calendar year end. Is it too late to amend for a 12/31/19 plan year end? They extended their taxes so would still have time to make payment. Or did they have to amend before 12/31?"
2 replies   |    42 views   |    Add Reply

DDB BN created a topic in 401(k) Plans

Suspension of 401k loan repayments

"We are getting many calls to submit the 12 month suspension request to the recordkeepers for loan repayments by participants who were laid off from their jobs. Would there be any advantage or disadvantage to waiting until closer to the end of the cure period to submit the 12 month suspension form to the recordkeeper?"
4 replies   |    89 views   |    Add Reply

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

California Disaster Area Declaration Sufficient for Hardship

"Can anyone confirm if the disaster area declaration for the state of California is sufficient for the new hardship reason for disaster areas. The hardship reason mentions that the employee's principal residence or principal place of employment was located in an area designated by FEMA for individual assistance with respect to the disaster. When I look up the declaration on FEMA for California I do not see dollars designated for individual assistance, only of Public Assistance. I see in the declaration though the dollars are available for "crisis counseling" for individuals. Does anyone know if we can apply the hardship reason here in California, assuming of course the plan was or will be amended timely. Thanks very much."
1 reply   |    38 views   |    Add Reply

pholosofizer created a topic in 401(k) Plans

CARES Act Distributions/Top Heavy

"Just curious on how others will treat the new distributions for top heavy testing purposes. The main concern is the ability for participants to contribute the funds back into a plan. If the money isn't paid back, I assume it'd just be treated like other in-service distributions. If the money is recontributed though, would these funds be ignored? Or would the balance associated with it be included in the top heavy balance (and then you'd probably have to back out the in-service so it's not double counted)? Thanks for your thoughts!"
1 reply   |    70 views   |    Add Reply

Stash026 created a topic in 401(k) Plans

CARES Act Eligibility Question

"I apologize if this has been asked before, but has it been established that if a spouse gets furloughed/loses hours a participant falls under the "adverse financial consequences" to determine eligibility for the in-service distribution/loan under the CARES Act? Thanks everyone!"
2 replies   |    84 views   |    Add Reply

Stash026 created a topic in 401(k) Plans

EBAR Calculation - Cash Balance/Profit Sharing

"I believe I have the answer, but can't seem to find the actual language so I apologize. In the 401(k) + Cash Balance Situation, when calculating the EBAR to test both plans combined would you include the 3% Safe Harbor in the equation? Again, I apologize if it is a simple question just can't seem to put my fingers on it. Thanks again everyone!"
2 replies   |    51 views   |    Add Reply

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

COVID-19 Withdrawal

"Available for DB plans? I assume plans would need be amended to include a withdrawal provision and then add the $100K COVID-19 language?"
2 replies   |    56 views   |    Add Reply

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

Required THM for Plan when CB Plan is Frozen

"If a plan sponsor maintains both a cash balance plan and a defined contribution plan and the plans are top heavy, it is my understanding that the top heavy minimum must still be funded, regardless of the DB plan's frozen status. But my question is, would that contribution amount be 3% or 5% and would the amount depend on the contributions funded by the Key employees?"
2 replies   |    36 views   |    Add Reply

austin3515 created a topic in 401(k) Plans

CARES Act Loans/Distributions - SMM's Needed?

"So client amends the plan to add all of these wonderful new options. What are the obligations to tell the participants about the options? I happen to think we should be telling them about the options proactively. Perhaps that is based on more on ethics than law though. What is the law?"
5 replies   |    66 views   |    Add Reply

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