Message Boards Digest

June 10, 2020

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

King of Queens created a topic in 401(k) Plans

Match Allocations and Annual Compensation Limits

"The plan sponsor has a 401(k) Plan that provides a match formula equal to of 100% of the first 6% contributed. The contributions are deposited semi-monthly. Assuming the HCE has not received the maximum match allocation of $17,100 (6% of $285,000) at the time the compensation reaches the $285,000 limit, would the HCE be entitled to additional match allocations on deferral contributions for compensation earned over the $285,000 limit? The plan has no true-up provision and the document defines the match determination period as 'each payroll period' and not 'the Plan Year'. Some people say the match allocation must stop when the compensation reaches to $285,000 limit. Others say the match allocation can continue (up to the plan formula maximum) on compensation in excess of the $285,000 as long as there are corresponding deferral contributions. Should the match allocations stop or should they continue?"

5 replies   |    68 views   |    Add Reply

Gilmore created a topic in Distributions and Loans, Other than QDROs

Avoiding Income Tax on a January 2020 RMD Distribution

"Has there been any rollover relief offered for participants who took their 2020 RMD in January and would like to roll back into the plan (or IRA)? I know they missed the 60 day rollover window and don't fall under the April 1 to July 14 extension to July 15, but was wondering if I missed any further guidance on the January distributions."

6 replies   |    55 views   |    Add Reply

Flyboyjohn created a topic in Health Plans (Including ACA, COBRA, HIPAA)

Insurer Premium Rebates/Reductions = MLRRs?

"Some health insurance carriers are reducing premiums or providing rebates due to lower utilization of medical services so the issue arises whether the employer has to 'share' the savings with employees. My view is that these are essentially an advance payments of Medical Loss Ratio Rebates that the insurers would normally be sending later in the year, and therefore need to be 'shared' with employees as we do with MLRRs. Anybody taking a contrary position?"

2 replies   |    34 views   |    Add Reply

sb0828 created a topic in 401(k) Plans

Hardship Withdrawal Due to Pandemic

"Since FEMA declared a state of emergency for all 50 states due to Covid-19, does this mean that all participants of all 401k plans which allow for hardship withdrawals are eligible to take a hardship withdrawal pursuant to the following hardship withdrawal reason? "Expenses incurred on account of a federally declared disaster."

6 replies   |    74 views   |    Add Reply

Linda Wilkins created a topic in Correction of Plan Defects

Our Recent Experience with a VCP Submission

"We had wondered how long the IRS is taking during this pandemic to process VCP applications, and thought others might be interested. Here is data from one of ours: January 23, 2019 submitted; June 11, 2019 acknowledgement from IRS; April 17, 2019 IRS requests additional information; May 18, 2019 we respond' May 19, 2020 VCP compliance statement (1 year after last contact)."

0 replies   |    68 views   |    Add Reply

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Buford GA

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