Message Boards Digest

April 27, 2020

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

TPA created a topic in 401(k) Plans

Relief Measures for Safe Harbor Match Plans?

"Have any relief measures been put into place for Safe Harbor Match Plans that are also Top Heavy? Company is looking for ways to manage their costs during this time."

1 reply   |    64 views   |    Add Reply

Continuously Updated ASC Responses to Your COVID-19 Questions

Sponsored by ASC
How does the CARES Act affect retirement plans? Is the IRS extending 403(b) & DB plan restatement deadlines? ASC answers all of your questions and concerns. View the COVID-19 Plan Document & Administration FAQs Here.

Peter Gulia created a topic in Form 5500

If DOL Doesn't Grant Extension of July 31 Deadline -- So What?

"Even in years with no disaster or public-health emergency, many administrators of employee-benefit plans -- whether acting directly, or by some agent -- routinely extend a Form 5500 due date from July 31 to October 15. If the DOL doesn't grant an extension due to the coronavirus, is there a practical consequence beyond the make-work of completing and sending an extension form?"

3 replies   |    58 views   |    Add Reply

Dougsbpc created a topic in Retirement Plans in General

Partial Plan Termination During 2020 Despite Rehiring the Furloughed Employees Before Year-End?

"Have an employer who terminated 35% of participants. If this coronavirus situation improves by November, they may hire half of the terminees back. Apparently there is no special coronavirus exception to the partial plan termination rules. This is a plan year determination so we really do not need to determine whether a partial plan termination has occurred until after 12/31/2020 in this case. The employees where all laid off on March 28. Since these days most former employees want their distributions immediately, how are others handling this? My thought is if someone is 40% vested, they get paid their vested benefit now and if it is later determined that a partial plan termination has taken place, they subsequently get paid their remaining 60%. Does this seem reasonable? What if it is later determined a partial plan termination has occurred and their remaining 60% was worth $20,000 when they received their distribution, but it turned into $10,000 by the time they received their subsequent distribution due to plan investment losses?"

4 replies   |    74 views   |    Add Reply

Gilmore created a topic in 401(k) Plans

Paycheck Protection Program (2019 Contributions?)

"I saw the great discussion on the PPP earlier in the week, pertaining mainly to prefunding 2020 contributions. Are 2019 contributions eligible for consideration in the PPP? For example, employer was planning to fund a 2019 profit sharing contribution by their 2019 extended tax filing deadline, and makes the deposit during the 8-week window."

2 replies   |    55 views   |    Add Reply

gregburst created a topic in Mergers and Acquisitions

Plan Sponsor Acquired by Another Plan Sponsor; Buyer's Plan Doesn't Want Transfer of Roth Accounts

"Company A recently purchased all the stock of Company B. Company B was a subsidiary of a big conglomerate and participated in their 401k, which included Roth contributions. Company A's plan does not allow Roth, and they'd like to keep it that way. They don't even want the Roth rollovers coming into their plan. Company B employees were not given distribution options. They were told that all funds would be transferred to Company A's 401k (before Company A had considered the Roth issue). They would prfer to bring over all assets EXCEPT Roth. Is that allowed? Can the merger instrument state that only non-Roth assets will be merged, such that the Roth assets would need to remain where they are?"

1 reply   |    45 views   |    Add Reply

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

RMD to Older Designated Spouse Beneficiary (Death Prior to 2020)

"Pre-SECURE Act rule inquiry (based on a fictitious couple): participant dies at age 90 (after starting RMDs). Surviving spouse is the sole designated beneficiary, who dies at age 99. ULT factor in year of death for participant is 11.4. SLT factor in year after death for surviving spouse is 2.9. So factor in year after death is max (11.4 - 1, 2.9) or 10.4, which is then subtracted by 1 each year thereafter?"

0 replies   |    22 views   |    Add Reply

pb5350 created a topic in Defined Benefit Plans, Including Cash Balance

5307 Applications and COVID-19 Closures

"Most IRS offices are closed. I have a few DB plans for which we will need to file a Form 5307 application. The IRS website says they 'continue to process determinations for employees plans,' but it's not entirely clear what that means. ( Obviously, I will push the application submission dates off as far as possible, but does anyone know if U.S. Mail and/or FedEx/UPS packages are currently being delivered/accepted?"

0 replies   |    23 views   |    Add Reply

JRSP533 created a topic in 401(k) Plans

Balance for COVID Distribution

"Our company announced our plan was being amended for CARES over the next few weeks and participants can expect the changes to be adopted. Just curious if anyone knows what balances are typically available with these things as standard (I realize there not one necessarily). Vested/invested, employee/r contributions, etc. -- I never knew there were so many categories for a 401k balance. I'm fully vested and mostly wondering what categories might be unavailable when the plan is rolled out. For example, the available for a 'hardship withdrawal' currently is only $44k but vested balance is significantly higher than that."

2 replies   |    43 views   |    Add Reply

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

View job as Advisory Services Representative Advisory Services Representative  View details

The Standard
Cincinnati OH / Portland OR

►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