Dave Baker created a topic in Form 5500
"Thanks very much to @Bill Presson for bringing this matter to everybody's attention recently (DOL says we should not include participant names and other "Personal Identifiable Information (PII)" on the Schedule 8955-SAA, for example) -- here's a link to an article by Nevin Adams with details:https://www.asppa-net.org/news/dol-stop-including-pii-form-5500-filings"
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5500sorBust created a topic in Form 5500
"If I am a 5500-SF filer and my plan invests in the Pooled Separate Accounts of an insurance company, is the insurance company required to provide my TPA with Schedule A information? I understand that I'm not filing a Schedule A as part of my 5500-SF, but should the insurance company be providing full Schedule A information, or just information regarding commissions?"
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carelessostrich created a topic in 401(k) Plans
"Plan document specifies that subaccounts containing pre-tax earnings or contributions can be in-plan converted by eligible rollover distributions, into designated Roth subaccounts. Voluntary after-tax contributions go into a subaccount that's separate from elective deferrals and employer contributions. Does a subaccount still count as pre-tax if it doesn't actually contain any pre-tax earning or contributions, but otherwise can potentially contain pre-tax earnings? It's clearly not a designated Roth subaccount. In-service distributions otherwise not permitted."
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Jakyasar created a topic in Defined Benefit Plans, Including Cash Balance
"The normal 5500 filing was due by 4/30/2020, which was automatically extended to 7/15/2020 (if Form 5558 had been filed, it would have been the same deadline). What's the deadline to certify AFTAP -- 6/30/2020 or 7/15/2020?"
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Jakyasar created a topic in Retirement Plans in General
"Client files the LLC (single member - Schedule C) tax return on 4/15 with no extension but the return had been extended to 7/15/2020. I just found out that additional contributions will be required for 2019. Because the filing was extended to 7/15/2020 with no extension filing requirements, the client can make the additional contribution and deduct for 2019, i.e., redo the tax return -- correct?"
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D.J. Simonetti created a topic in Retirement Plans in General
"I have noticed that some plan administrators have been approaching employers about PEPs they're planning to make available in time for the 2021 effective date. Does anyone have an idea of how flexible or inflexible the PEPs are likely to be regarding an employer's preferences concerning eligibility, vesting, contribution formulas, loans, in-service distributions, etc.? None of the literature I have found on PEPs discusses this issue but flexibility in plan design would seem to be very important to an employer considering a move from a single employer VSP to a PEP."
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Jakyasar created a topic in 401(k) Plans
"Client made the 2019 deferral deposits pretty much 15-30 days after the payroll dates. I assume 7th business day as the safe harbor deposit date. Document is silent on when the deposits need to be made. This seems to be the standard. I am aware of the 'as soon as feasible' clause which varies from employer to employer. My understanding from the VFCP section 5(b) and the questions based on the 'online calculator' page: - Principal amount is the per payroll deduction, e.g., 3/1/19 for $200
- Loss date is the 7th business date from payroll date 3/11/19 (included 3/1 as the first business date)
- Recovery date is the date of the deposit 3/18/19, i.e., 6th business day from loss date
- Final payment date -- assuming the same as recovery date -- I could not find anything on this as a definition.
Questions: - Are the dates correct as calculated above?
- The interest added by the employer to make up the missed dates, are they deductible? If yes, what year (assume 2019 tax return not yet done)?
- As this additional interest correction is added to the assets, which plan year's 5500 filing should reflect them? Assume 2019 5500 filing is not yet completed.
- What if, during 2019, assets had a negative return -- or a 25% return -- does it matter how the assets perfomed?"
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ChristineGarcia created a topic in Qualified Domestic Relations Orders (QDROs)
"I am a federal employee and am going to retire in 5 years. I was married once. We finalized a DIY divorce with a help of onlinedivorcer.com and during the time of marriage (or after that was over) we didn't sign any papers regarding my retirement plan or pension. The divorce was over 3 years ago. We were married 3 years. We don't have any common assets or property or kids. My present-day girlfriend keeps pushing the wedding because she is sure that some part of my pension would go as a spousal support to my ex-wife according to the Texas state laws. Neither QDRO nor any other documents regarding my pension were signed. I am interested whether that's true. Am I going to lose a couple of grand monthly and what should I do if it's for real? What happens if I get married again?"
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Belgarath created a topic in Communication and Disclosure to Participants
"DOL recently said 'The new safe harbor is an additional method of delivery and does not substantively change the 2002 safe harbor.' Nice that it takes them 150 pages to issue a regulation that doesn't 'substantively' change the existing one. Our tax dollars at work! Now, to be fair, I haven't read it, so maybe it provides more help than I expect. Since my expectations are very low, that's possible..."
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