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Message Boards Digest

April 7, 2021

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

Molgilny89 created a topic in 401(k) Plans

No Social Distancing Here -- OK to Commingle Assets of Multiple Solo 401(k) Plans?

"Would there be anything legally preventing a recordkeeper from commingling the assets of multiple Solo 401(k)s into a single trust account to achieve efficiencies for the all the individual plans? I know certain parts of ERISA do not apply to a Solo 401(k) plan, but I'm wondering if any of the sections that do apply would prohibit this practice?"

4 replies   |    64 views   |    Add Reply
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Jennifer D. created a topic in 401(k) Plans

Change a Safe Harbor Formula Mid-Year?

"Can a plan go from a 3% non-elective Safe Harbor contribution to a flexible (maybe) 3% safe harbor contribution mid-year? Would it need to provide a seperate notice for this under the SECURE Act, or can the plan sponsor just make the change when writing the Cycle 3 document?"

1 reply   |    36 views   |    Add Reply

Vlad401k created a topic in 401(k) Plans

Show a Deemed Distribution on Form 5500 Line 10g?

"A participant had a loan default in 2020 and there was a deemed distribution (he was still employed but not repaying the loan). I understand that the deemed distribution amount needs to be shown on Line 8e on Form 5500 and the Ending Balance should not include that loan amount. However, would you still include the amount of the deemed distribution on Line 10g ('Did the plan have any participant loans?')?"

0 replies   |    41 views   |    Add Reply

pam@bbm created a topic in 401(k) Plans

How to Record Plan Net Credits on Form 5500-SF?

"Several of our plans use the Empower platform and receive plan net credits. Empower reports this as negative fees. On the Form 5500-SF is it correct to report this as a negative expense under Administrative service providers?"

4 replies   |    60 views   |    Add Reply

Peter Gulia created a topic in Retirement Plans in General

What If the Plan Administrator Didn't Know a Participant Had Died?

"The Internal Revenue Manual directs an Employee Plans examiner not to challenge a plan for failing to meet Section 401(a)(9) if the plan's administrator could not locate the distributee after a diligent search that included IRS-specified steps.

[IRM 4.71.1.4(15)(d) -- see online]

But that direction does not speak to a situation in which an individual-account (defined-contribution) retirement plan paid no involuntary minimum distribution because the plan's administrator didn't know the participant had died. Should the IRS relax strict adherence to Section 401(a)(9) if the plan's administrator shows it followed reasonable procedures to detect participants' deaths? What should those procedures be? How often does it happen that no one has filed a claim within ten or eleven years after a participant's death?"

5 replies   |    45 views   |    Add Reply

Stash026 created a topic in 401(k) Plans

SEP + Profit Sharing or Cash Balance

"I have a new client that is currently maxing out a SEP, but has the opportunity to start a Profit Sharing or Cash Balance Plan. I don't believe the SEP has any bearing on the maximum contribution into the other plans, because the companies are unrelated, but I want to make sure someone could max out both a SEP and a Profit Sharing (or receive a contribution in a Cash Balance)."

4 replies   |    35 views   |    Add Reply

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