Message Boards Digest

May 13, 2022

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

mariemonroe created a topic in 409A Issues

Can Plan Allow Distribution Event to Be the Later of the Separation from Service or a Specified Date?

"Can plan allow distribution event to be 'later of' separation from service or a specified date?"

1 reply so far   |    Click Here to Add a Reply

rblum50 created a topic in 401(k) Plans

Late Employer Contribution to 401(k) Plan

"I have a 401(k) plan that had a required contribution of about $55,000 for Plan Year 2020. This required contribution didn't get deposited until 4/22/22.

Given the pandemic and a downturn in business, even though the client wanted to make this contribution in a timely manner, the soonest they were able to make the deposit was late this past April.

I would love to hear from someone who's had a client in the same situation. I suspect this is a somewhat common situation. What they did about it? Also, if the IRS got involved, what relief were they willing to give?"

3 replies so far   |    Click Here to Add a Reply

austin3515 created a topic in Relius Administration

Where to Get Lifetime Income Numbers?

"So we asked Relius why we could not get our Lifetime income numbers to work and they said:

'Prior to generating any reports or results, the user must download needed tables and updates into Relius. These are global and are done by choosing Utilities / Update Global Tables from the main menu. The two tables are (a) the Ten-Year Uniform Life and (b) the Ten-Year constant maturity Treasury (CMT) securities yield rate for the first business day of the last month of the period to which the benefit statement relates. These rates must be updated monthly and are available from FIS. They are typically available for download by the fifth business day of the following month.'

What they don't mention is WHERE we get the rates. Anyone know? Also would anyone know what the math is to caluclate the benefits if say I needed to do it in Excel?"

1 reply so far   |    Click Here to Add a Reply

Lucky32 created a topic in Distributions and Loans, Other than QDROs

In-Service Withdrawal After a Period Certain But Investments Have Dropped Substantially

"A plan with a pooled arrangement allows in-service withdrawals for amounts that have accumulated for at least two years in the plan. What would be the best way to determine the amount for such a withdrawal at this time because account balances are lower now than they were two years ago due to the market's volatility over the last few months?

Because there won't be a 2022 contribution, basing the withdrawal on the balance from two years ago could result with a distribution from a participant's account exceeding their 1/1/22 balance. Doing an interim valuation on this sizable plan just because one participant requests an in-service withdrawal seems unreasonable. I'm hoping there's a better solution."

1 reply so far   |    Click Here to Add a Reply

Lou81 created a topic in 401(k) Plans

Two Employees Mistakenly Not Offered Opportunity to Defer

"I have a client who was reviewing entry and discovered they missed two employees who were eligible 1/1/2022. They are going to provide the enrollment information ASAP. There is no match, so just the missed deferral If the employees return the forms and indicate they do not want to defer, do you still have to provide a QNEC for the MDO? Their NHC ADP average is low, if they return the form and want to defer 10%, can I use that percentage for my correction instead of waiting until next year when I do the ADP test?"

No replies yet   |    Click Here to Add a Reply

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

Safe Harbor 403(b) Plan, but.....

"So our firm took over the audit of a 403(b) Plan, YE 12/31/20 (yes, 2020, don't ask). The plan document we have shows that it is written as a 'Safe-Harbor' 403(b) Plan, with a match equal to 100% of deferrals on the first 3% of compensation and then 50% of deferrals on the next 2%. However, in going into the participant testing, the first person picked for testing had $19,500 of deferrals, OK. When the match was tested, the matching contribution was equal to 5% of compensation, not 4%. Anomaly? No, anybody with greater than 5% of deferrals received a 5% match.

We noted that the document does allow for a matching contribution, and it's defined as discretionary. Question brought up is: Can the extra 1% be considered a discretionary match, and, what, if any, ACP testing would have to be performed?

To complicate matters, there is no TPA retained by this employer, so it is a big old mess."

1 reply so far   |    Click Here to Add a Reply

cpc0506 created a topic in 401(k) Plans

After-Tax (Voluntary) Contributions to a Safe Harbor Match Plan

"Client is looking to add after-tax (voluntary) contributions to their current safe harbor match plan. I understand the ACP testing and top heavy issues that arise with after-tax contributions, but I'm trying to determine whether the client is required to provide the safe harbor match to the after-tax contributions. Can you help?"

1 reply so far   |    Click Here to Add a Reply

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