Message Boards Digest

April 30, 2020

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

AmyETPA created a topic in Operating a TPA or Consulting Firm

What Documents Should a TPA Keep, for Purposes of a PPP Loan Application?

"For small sized TPAs, what kind of backup material, if any, are you keeping on file to support your PPP need for the loan application? Ours was approved but we are wanting to be sure that we are able to prove that it was needed."

1 reply   |    48 views   |    Add Reply
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cbadmin123 created a topic in 401(k) Plans

Overdeduction by Payroll Department Causes 402(g) Problem

"An employee met their annual limit for 401k but the payroll was configured incorrectly and so there was one more deferral, above the annual limit. Recordkeeper says IRC 402(g) applies but -- with the market how it is -- it doesn't seem fair the employee would take a loss on their excess distribution because it was the employer's mistake. Is there another solution? I'm thinking about reversing the excess deferral plus earnings/losses through the plan and reversing the deduction through payroll so it's taxed properly for the employee."

2 replies   |    52 views   |    Add Reply

Pension RC created a topic in Defined Benefit Plans, Including Cash Balance

Include Accrued Dividends in Market Value of Assets?

"My understanding is that, for valuation purposes, accrued dividends are not included in the market value of assets. Is that correct?"

2 replies   |    67 views   |    Add Reply

justatester created a topic in 401(k) Plans

414(s) Testing for 'Base Pay' Plan under Puerto Rico Code

"We have a PR plan that uses base pay for the definition of compensation. So there is some excluded compensation. Does this require 414(s) testing? Does it matter if it is dual qualified? Do you have the PR code reference?"

0 replies   |    18 views   |    Add Reply

Belgarath created a topic in 457 Plans

'Substantially Equal' Monthly Installments Under a 457(b) Plan

"Curious as to how this is handled in most plans -- specifically, tax exempt plans with no Rabbi trust. Some plans allow participants to direct 'their' account (although of course it is employer money) but others don't. When it comes time for the participant to elect a distribution, and they choose 'substantially equal' monthly installments, do the plans you see: [1] Take the account balance at the time of distribution, divide by the number of months, and pay a fixed payment -- interest or losses on the funds absorbed by the employer; or instead [2] allow the participant to have investment control, and the 'substantially equal' payments can fluctuate with the underlying market value? Or some other option?"

1 reply   |    29 views   |    Add Reply

austin3515 created a topic in 401(k) Plans

Bonuses Are 'Taxable Fringe Benefit' for Safe Harbor Comp Purposes?

"I personally do not consider a 'length of service' bonus paid to be a taxable fringe benefit but I am encountering a plan where it was treated as a safe harbor comp exclusion taxable fringe benefit. To add a little more color, people who have been with the company 0-5 years get nothing, between 5 and 10 get $1,000, between 10 and 15 get $2,000, etc. This is a Safe Harbor Plan, and I'm tying to determine if the definition meets a 414(s) safe harbor definition of compensation."

1 reply   |    46 views   |    Add Reply

NQS created a topic in Retirement Plans in General

Funding Deadline Extension to 1/1/2021 -- Available to Money Purchase Plans?

"The extension of the funding deadline until 1/1/2021 is only for defined benefit plans, not money purchase pension plans -- is that right?"

1 reply   |    34 views   |    Add Reply

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