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Message Boards Digest

June 1, 2020

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

Peter Gulia created a topic in Communication and Disclosure to Participants

Should an Employer Assign an Email Address for Every Employee (Even Those Who Won't Use It Daily)?

"Another BenefitsLink discussion includes some observations about how much or how little help the new Default Electronic Disclosure rule offers if an employer/administrator lacks email addresses for the portion of participants who are severed from employment. A 2002 rule allows electronic delivery if, with other conditions, the employee/participant can access the communications using an email system the employee uses as 'an integral part' of the employee's work for the employer. Under last week's new rule, there is no such 'integral part' condition and an employer-provided electronic address can be enough to invoke the new regime if the employer assigns the address for some employment-related purpose beyond the retirement plan's communications. A retirement plan's administrator may continue to rely on such an address (if there is no bounce-back or other operability defect) after a participant's severance from employment.

If an employer/administrator seeks to grow the population of (future) former employees who can remain in the new electronic regime, should an employer assign an email address for every employee? (Imagine an employer tells its employees that human-resources and safety announcements will be sent to employees' employer-provided email addresses.)"

12 replies   |    85 views   |    Add Reply
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Barry K created a topic in Plan Document Amendments

National Provider Has Stopped Sponsorship of My Profit Sharing Plan Document

"I'm a sole proprietor that has a Prototype Profit Sharing Plan that was abandoned by a national provider. Can someone recommend a provider that offers Prototype plan documents?"

2 replies   |    69 views   |    Add Reply

JOH created a topic in Retirement Plans in General

Determination of Account Balance While Participant Loan Is Outstanding

"Participant has vested balance of $90,000. Takes out a loan for $35,000. We display their account balance now as $55,000 and a loan balance of $35,000. Six months later, Participants wants to take a second loan. The second loan calculation would be based on the $90,000 ($55,000 account balance plus the $35,000 loan balance) and not just the $55,000 account balance, right?"

5 replies   |    116 views   |    Add Reply

glhotdog created a topic in 401(k) Plans

Mid-Year Safe Harbor Match Under PPP

"Plan Sponsor maintains a Safe Harbor 401(k) Plan with Basic Safe Harbor Match. Safe Harbor match is calculated annually per plan document. Plan Sponsor would like to calculate safe harbor match for the period covered under the PPP Loan which they received. Should this safe harbor match be calculated for the PPP period and can it be allocated to the participant's directed account at their asset custodian?"

1 reply   |    56 views   |    Add Reply

Ponderer33 created a topic in Other Kinds of Welfare Benefit Plans

Sponsor Retiree HRAs with No Trust Account?

"Other than the risk of bankruptcy or other loss, is there any problem with an employer sponsoring a HRA for eligible retirees with notional accounts tracking reimbursement from current operating funds?"

0 replies   |    7 views   |    Add Reply

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