Message Boards Digest

March 4, 2021

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

cheersmate created a topic in 401(k) Plans

NRA = 65 + 5P and 100% Vesting

"A Calendar Year retirement plan with 2/20 vesting defines its 'Normal Retirement Age' as the later of age 65 or 5 Years of Plan Participation, and, hired the following Eligible Employee:

Hire 3/1/2020

Birth 4/1/1957 (age 62, 11 mos at hire)

Eligible 6/1/2020

NRA based on the above definition is 1/1/2025 (1st day of plan year of 5th anniversary of participation) Assuming he works 1000+ hours in every year and is actively employed, [1] this employee would not be 100% vested on his 65th birthday (4/1/2022) because he has not yet satisfied the definition of Normal Retirement Age, correct? [2] On 12/31/2024 this employee is 80% vested, and on 1/1/2025, this employee's vesting would be accelerated to 100% Vesting upon reaching Normal Retirement Age, correct?"

1 reply   |    47 views   |    Add Reply

khn created a topic in 401(k) Plans

Switch Recordkeepers but Keep Prior Recordkeeper's Prototype Plan Document?

"When a plan switches recordkeepers, are they able to remain on the same plan document, even though it may be a prototype document for the recordkeeper they're leaving? We have a plan that is moving to a recordkeeper that provides no plan document support, so does this mean the only option is for the employer to move to an individually designed document, or can they use the one they're currently on?"

16 replies   |    95 views   |    Add Reply

pmacduff created a topic in Cross-Tested Plans

415 vs. Catch-up (Again!)

"I know this topic has been addressed repeatedly, however this time of year I sometimes need a refresher. For 2020 participant over age 50 contributes $22k in deferrals. Compensation is $270,318.33. Match contribution is $10,812.73. Can this participant receive a profit share allocation of $30,687.27 in order to reach a total allocation amount of $63,500?

Years ago I used to think the participant was limited in his total allocation amount under 415 because he only contributed $2,500 over the deferral limit of $19,500. However I was later advised that you can recharacterize the full $6,500 in catch-up to compute the 415 limit. In other words, talking about two different tests and what gets recharaterized in that particular test (415 vs ADP for example). Do others agree that my participant can get $30,687.27 in profit share?"

5 replies   |    41 views   |    Add Reply

Rebecca K. created a topic in 401(k) Plans

Top Heavy Plan with Match But No 2020 Profit Sharing Contribution

"Plan is top-heavy; has a 3% non-elective safe harbor contribution; has a stated match of $0.25 for each dollar deferred up to 4% of pay for Non-HCE only; has last day/1000 hour requirement; has a discretionary profit sharing plan, but the plan sponsor has decided NOT to make a profit sharing contribution for 2020.

I know if they make a profit sharing contribution (which they always have in the past) that they would need to satisfy top-heavy minimums, but in 2020 they are not going to make a profit sharing contribution. For 2020, do they need to satisfy the top-heavy minimums? I know that adding allocation requirements to a match makes nondiscrimination more difficult to pass, but does the fact that the match is for non-HCE only help?"

4 replies   |    44 views   |    Add Reply

Chippy created a topic in Retirement Plans in General

Too Much Allocated to Participant's Account

"In 2019 a participant in a profit sharing plan received the full contribution when they should have received only the 3% top heavy minimum due to working less than 1,000 hours. To correct the error, can the excess allocation be taken out of the participant's account (a brokerage account)? If the employer wants them to keep it, can the plan be amended to allow it?"

10 replies   |    45 views   |    Add Reply

DPSRich created a topic in 401(k) Plans

Which Form to Use for 2020 -- 5500-SF or 5500-EZ?

"I have a few clients who have a 401(k) plan that uses a safe harbor match. The principals defer but the rank-and-file employees do not. So some participants have a zero account balance. I tried e-filing a Form 5500-SF showing 2 active participants but only 1 that has an account balance. rejected the submission. The support desk tells me to file Form 5500-EZ. I'm not comfortable doing that. Any suggestions and references will be greatly appreciated."

3 replies   |    38 views   |    Add Reply

PS created a topic in Plan Terminations

Terminating a 403(b) Plan That Uses a Group Annuity

"I'm assisting with a 403(b) plan termination for the first time. It has a GCA (Group Custodial Agreement). How different is such a termination process compared to a 401(k) plan? Some participants have outstanding loans. When a 401(k) plan terminates, the participants are allowed to roll over the loans into an acquiring company's plan. How would that work with a 403(b) plan with a GCA?"

0 replies   |    8 views   |    Add Reply

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