Message Boards Digest

February 3, 2022

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

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

Cash Balance Plan-- Pay Credit Must Be Deposited for a Terminated Participant?

"Brand new CB plan, effective 1/1/2021. For vesting (3 year cliff), no prior service is provided. Participant enters the plan on 1/1/2021 with pay credit of $1,000. Accrues 1,000 hours but terminates during the year. Thus 0% vested. Accrues the pay credit and the equivalent AB is used to pass 401(a)(26). However, at end of year, his pay credit is forfeited due to 0% vesting, thus account balance is $0 at end of year. Does the plan sponsor need to make a deposit of $1,000 on this person's behalf? Assume minimum required contribution requirement is not an issue, whether this $1,000 is deposited or not."

9 replies so far   |    Click Here to Add a Reply

Jester created a topic in 401(k) Plans

Take Out P.S. 58 Cost as an In-Service Distribution?

"Aa participant in a 401(k) plan with life insurance has cumulative P.S. 58 costs. He's age 75 and wants to take out his nontaxable P.S. 58 cost as an in-service distribution. Can that be done? The life insurance is still effective and the P.S. 58 cost is being calculated and taxed annually. Taxable RMD is being taken as required."

3 replies so far   |    Click Here to Add a Reply

John P created a topic in Mergers and Acquisitions

Looking for a Banker Who Focuses on TPA M&A

"We want to find a great M&A advisor for the TPA industry. The ideal profile is this advisor is well known in the TPA industry and has done many deals. Please let me know if anyone comes to mind."

No replies yet   |    Click Here to Add a Reply

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

No Surprises Act Notices-- In-House Web Portal Is Sufficient?

"The No Surprises Act requires that health plans 'post on a public website of the plan or issuer' their No Surprises Act notices. In the employer-sponsored plan context, does that mean that an employer can satisfy this requirement by posting the notice on its internal intranet or similar site that employees can access?

Many of the commentators that I have read said that it's acceptable. That makes some sense because I don't think that a participant would ordinarily think to go to the employer's general website for health plan information. But what about non-employee participants, such as those participating in the plan through COBRA? Would an employer who does so be complying with its notice obligation with respect to those employees?"

2 replies so far   |    Click Here to Add a Reply

Jakyasar created a topic in Retirement Plans in General

Adding a DB Plan for 2021 to an Existing Profit Sharing Plan-- How to Coordinate Top Heavy Minimums?

"Employer has an existing PS plan. Now wants to add a DB plan for 2021. DB plan by design will state that the PS plan will provide top heavy, but PS plan has no provisions on how the 'top heavy duplications when a DB plan is maintained' checked. In general, depending on the document type, I would put in very detailed language explaining that the top heavy will be satisfied under the PS plan, and how. For 2021, is the DB plan on the hook for top heavy? There's no way to retroactively amend the PS plan for 2021, correct?"

3 replies so far   |    Click Here to Add a Reply

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