Message Boards Digest

May 26, 2020

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

Dave Baker created a topic in Form 5500

Don't Put Personally Identifiable Information on Form 5500 and Schedules

"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:"

0 replies   |    49 views   |    Add Reply

5500sorBust created a topic in Form 5500

Schedule A Information for 5500-SF Filer

"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?"

0 replies   |    76 views   |    Add Reply

carelessostrich created a topic in 401(k) Plans

Is a Voluntary After-Tax Contribution Subaccount 'Pre-Tax'?

"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."

6 replies   |    102 views   |    Add Reply

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

AFTAP Certification Deadline

"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?"

2 replies   |    43 views   |    Add Reply

Jakyasar created a topic in Retirement Plans in General

Deduction for Additional Contribution After Filing of Tax Return

"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?"

3 replies   |    74 views   |    Add Reply

D.J. Simonetti created a topic in Retirement Plans in General

Pooled Employer Plans

"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."

3 replies   |    73 views   |    Add Reply

Jakyasar created a topic in 401(k) Plans

Late-Deposited Deferrals -- Questions on Earnings Calculation and Effect on Form 5500

"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.


  • 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?"
3 replies   |    55 views   |    Add Reply

ChristineGarcia created a topic in Qualified Domestic Relations Orders (QDROs)

Uncontested Divorce and Retirement Plan

"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 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?"

2 replies   |    59 views   |    Add Reply

Belgarath created a topic in Communication and Disclosure to Participants

Meet the New DOL Safe Harbor -- Same as the Old DOL Safe Harbor?

"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..."

3 replies   |    38 views   |    Add Reply

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