Message Boards Digest

June 2, 2020

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

Ahuntingus created a topic in 401(k) Plans

Use 2019 Final 5500-SF Now, or Must Wait for the 2020 Version?

"Client terminated plan on 3/1/2020. All assets distributed to the 3 participants by 5/1/2020. Client wants to file final 5500-SF now. Question: Do we use the 2019 5500-SF as there is no 2020 5500-SF yet available?"

2 replies   |    46 views   |    Add Reply

sb0828 created a topic in 401(k) Plans

Loan Suspension under CARES Act: When Is First Payment Due, If I Take Out a Loan Today?

"If I am a 'qualifying participant' pursuant to the CARES Act, and I take a loan today and request a suspension of the payments, when would my first payment be due? I thought it would be June 1, 2021 (i.e., a full 12 month suspension), but I have seen a reference to January 1, 2021, and a separate reference to March 27, 2021, as the next payment date for any loan suspended as per the CARE Act."

1 reply   |    32 views   |    Add Reply

ktrombino created a topic in Correction of Plan Defects

Automatically Enrolled Prior to Being Eligible

"Two 19-year-old employees were automatically enrolled in the plan on February 1, 2020. The eligibility age is 21. They were both just terminated due to COVID 19 related matters. Their account balances are less than the total amount of employee deferrals contributed to date. What sort of correction would need to be made?"

2 replies   |    34 views   |    Add Reply

Alonzo Church created a topic in Retirement Plans in General

When Does a Self-Employed Owner 'Terminate' Employment?

"When does a self-employed individual truly have a termination of employment allowing him to take a distribution from his qualified plan? Is it: [1] When he moves from one type of business to another? (So he's effectively terminated is current trade or business) [2] When he runs the same type of business, but he significantly relocates it? As an example, suppose a real estate agent has moved from one agency to another. Is the trade or business -- my real-estate business with company x? Or is it [3] my real estate business?"

1 reply   |    33 views   |    Add Reply

ERISAGal created a topic in IRAs and Roth IRAs

Repayment of RMD Paid in Stock During 2020

"If a participant took an RMD in 2020 as a stock distribution and was determined to meet the CRD requirements, can that repayment during the 3-year window be made in the form of stock or does it have to be at the cash value of the stock on the date it was distributed?"

1 reply   |    24 views   |    Add Reply

austin3515 created a topic in 401(k) Plans

Administration of Hardship Amendment -- QNEC/QMACs Allowed

"We have been administering hardships as follows for our clients: -If the document said 'all sources' are available for hardships, then we allowed from QNEC/QMAC/Safe Harbor. If it said just Elective Deferrals then we've treated them as not eligible. This treatment appeared to us at least to be the most logical path forward.

The problem is that the Corbel/FIS Amendment forces us to choose a default of 'QNECs are available' or 'QNECs are not available' -- a binary decision which will lead to probably half of our amendments requiring employer sign off.

I prefer to have a formula that says 'If all sources is selected in the Adoption Agreement, then QNECs are available. If individual sources were selected in the Adoption Agreement, then QNECs are not available.'

What are others doing with this?"

2 replies   |    31 views   |    Add Reply

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