Message Boards Digest

August 5, 2020

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

Belgarath created a topic in 403(b) Plans, Accounts or Annuities

Vesting Upon Partial 403(b) Plan Termination

The information in this article, while interesting (and I didn't bother to evaluate it), makes no difference to us, as our plans provide for 100% vesting upon full or partial termination anyway. I expect most plans do."

2 replies   |    29 views   |    Add Reply
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Scuba 401 created a topic in Retirement Plans in General

Statute of Limitations Applies to 'Informal' Plan Disqualification?

"When is a plan actually considered disqualified? Does the IRS need to formally disqualify before it is considered disqualified? I know the IRS can reach back to open years but I'm wondering how the statute of limitations applies to plans that might not be qualified due to failures (but have not been formerly disqualified by the IRS)."

5 replies   |    71 views   |    Add Reply

AlbanyConsultant created a topic in 403(b) Plans, Accounts or Annuities

'Easy' Eligibility Question Crossing the Plan Year

"Calendar year plan, employee is hired during the last week of 2019. However, the first paycheck they receive isn't until the first week of 2020 (and counts on the 2020 W-2). Does the universal availability clause require that the participant be counted as a participant in 2019, even though there is no official 2019 compensation? And this plan has an ACP Test -- I would say that the participant had no opportunity to receive a match and therefore can't be counted in the 2019 ACP Test... but I would have to include them in a coverage test. I don't really have a basis for that (yet), but it seems ridiculous to include someone in a test that they had no opportunity to take advantage of (hmm, so then why include them in 410(b) testing?). Any sage advice?"

2 replies   |    37 views   |    Add Reply

JustMe created a topic in Governmental Plans

Restatement of Governmental Plan Documents: When Due?

"Are governmental defined contribution plans subject to the 6-year restatement period? If so, are their restatements due at the same time as 401(k), profit sharing and money purchase plan restatements (July 31, 2022)?"

2 replies   |    35 views   |    Add Reply

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