Message Boards Digest

June 11, 2021

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

BG5150 created a topic in Form 5500

Plan Sponsor's Name Changed by One Letter

"Company name: 'Two River Phrenologists' On 5500 and plan docs over the years (for whatever reason) it was listed as 'Two Rivers Phrenology.' The plan has an identical naming issue. We're correcting the plan docs going forward and will make the change on the 2020 Form 5500. Will I have to complete question 4 about the name change? Or will it not matter, that one little letter?"

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Jakyasar created a topic in Retirement Plans in General

Uncertain About Form 8955-SSA Filing Requirements

"I'm no expert on 8955-SSA but I had a discussion with a TPA. Whenever there is a termination of a participant and the participant is not paid out by the end of the plan year following termination, I file Form 8955-SSA, regardless of plan type.

Our discussion was about the 'deferred benefit,' which the TPA stated is only applicable when the benefit/account balance is not due until NRA, i.e., the plan does not pay benefits until NRA.

Also, TPA stated that if only a 401k/safe harbor plan, then no need to file a Form 8955-SSA (all benefits are 100% vested at all time).

Is this correct per instructions 'Plan administrators of plans subject to the vesting standards of section 203 of ERISA must file Form 8955-SSA.'? Are there any situations where 8955-SSA is not required to be filed for any qualified DC and/or DB plans?

Let's leave 403b plans out and this is a question for DC or DB plans. Terminated participants may have partial or full vested benefits. Does it matter if the DC plan is a money purchase plan or a profit sharing plan where the normal form is J&S?"

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Sara Hotvedt created a topic in Form 5500

Reporting 'Back' Commissions on Form 5500 Schedule A

"I'm preparing a Form 5500 for a large welfare benefit plan. The agent informed me that one of the insurance companies failed to pay them commissions for several years and that, when this was discovered, they made one large payment of those commissions in 2020. Would I report the entire amount paid on the 2020 Schedule A even though a majority of the amount reported was actually for other plan years?"

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rocknrolls2 created a topic in Multiemployer Plans

Contributing Employer Merged Underfunded DB Plan into Multiemployer Fund -- Withdrawal Liability Arises?

"I represent a multiemployer defined benefit plan. Employer X previously maintained a single employer defined benefit plan for its collectively bargained employees. X negotiated the merger of its plan into the multiemployer plan in 2005. However, because there were certain underfunded portions of benefits under its plan, under a merger agreement between the union covering X's employees and X, X agreed to make contributions for the underfunded portion to the multiemployer plan over a 10-year period with interest. Instead, X made a lump sum contribution of the underfunded portion plus interest to the multiemployer plan in 2006.

X withdrew from the plan in 2019. In assessing X for withdrawal liability, the actuary treated the lump sum contribution to the plan as an employer contribution in determining the amount of X's withdrawal liability. X has filed a request for review of the fund's assessment challenging the treatment of the lump sum contribution as an employer contribution.

Does the multiemployer plan have a reasonable argument for its treatment of such amount as en employer contribution for purposes of X's withdrawal liability calculation?"

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Bri created a topic in Defined Benefit Plans, Including Cash Balance

PBGC Premium When One Alternate Payee Is the Only Head Left to Count?

"The instructions for the PBGC premium payments say that alternate payees are not included in the participant count. From what I read in the Code and ERISA, an alternate payee is defined as someone subject to a domestic relations order. Not specifically a QDRO.

Therefore, I suspect that for my 2021 filing, where the only benefit left to go as of 12/31/20 was for an alternate payee whose QDRO was signed by the judge in January, there's no participant count at all. (Actual participant took his 50% earlier in 2020.)

I'm not sure whether the January date that 'qualifies' the order might mean the sponsor has to pay 1/12 of a head-count charge. But because the domestic relations order really came about first in 2006 (it was signed by a judge then but incorrectly designed/worded -- not sure who reviewed it -- and never corrected until the past year with the payment pending upon plan termination), I think the sponsor has no premium due at all. (Obviously no VRP since all benefits have been completely paid now.) Sound correct?

I'm also thinking my participant count was 0 at year end 2020 and then as the BOY count on what will be their final 2021 Form 5500-SF filing as soon as the residual $40 in trust assets is liquidated and applied to administrative fees."

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cpc0506 created a topic in 401(k) Plans

Removing Fixed Match from Safe Harbor Plan

"Client is looking to remove a fixed non-safe harbor match of 100% of deferrals up to 6% comp (pay period determination period) from its plan. The plan also has a safe harbor match, so this is a safe harbor plan. Can we removed the fixed match so long as it is done prospectively (say 8/1/21) with no SH notice provided by July 1. Is this change a permissible mid-year change to a SH plan?"

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