Message Boards Digest

June 17, 2022

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

Puffinator created a topic in 401(k) Plans

4-Tier Integrated Profit Sharing Plan Calculation in Excel?

"Does anyone have a 4-Tier Integrated PS Calculation in Excel that walks one through the steps to calculation per tier? I am super rusty and want to make sure I do it correctly."

1 reply so far   |    Click Here to Add a Reply

metsfan026 created a topic in 401(k) Plans

Different EIN's for DB Plan and DC Plan Sponsored by Same Company?

"Have a potential client that's looking to setup both a DC and DB Plan. No issue in that, but where they are looking to invest the money is asking for separate EIN's for each plan. Is that normal?"

2 replies so far   |    Click Here to Add a Reply

52626 created a topic in 401(k) Plans

Safe Harbor Plan Can Merge with Another Safe Harbor Plan Mid-Year?

"Company A has a Safe Harbor Match Plan - 1 year of service requirement.

Company B has a non-Safe Harbor Plan - 2 months of service requirement.

Company A wants to merge Company B's plan into Company A's plan. Can a non-safe harbor plan merge into a safe harbor plan mid-year?

The only thing I've found is that it's OK when the surviving plan is safe harbor and a 'maybe' notice is provided.

Company A has a safe harbor match, so does it need to wait until January 1 to merge the plans?"

No replies yet   |    Click Here to Add a Reply

FAQ created a topic in Nonqualified Deferred Compensation

Grandfathered Deferred Comp -- Changing from Employee to Independent Contractor Status Causes a Termination Event?

"Has anyone seen guidance regarding paying out grandfathered deferred comp when the employee who deferred the compensation becomes an independent contractor? Per Section 1.409A-1(h)(ii) of the 409A regs, an employee is not considered to have a separation from service if he or she shifts from employee status to independent contractor status.

A client has a grandfathered 2003 deferred compensation agreement. The executive deferred the compensation until 'Retirement,' which has a rather loose definition. If the plan committee finds that the employee has had a cessation of services to the company that is deemed to constitute a retirement, then he has retired. The executive has scaled back his work level, is retirement age, and is ready to retire. The employer would like him to remain a consultant for a few years, likely working much less that he was as an employee. Both parties would like to treat him as retired for purposes of the deferred comp agreement.

It seems the 409A concept of separation from service should not be applicable. I am a bit rusty on my pre-409A deferred comp payment triggers and whether there is a well-defined concept of separation from service (I have not found one in any event). If in his new role he is truly a contractor as opposed to a common law employee, I believe he can reasonably be deemed to have retired and should be paid the deferred compensation that was deferred until his 'retirement.'"

No replies yet   |    Click Here to Add a Reply

R.J. Gage created a topic in Distributions and Loans, Other than QDROs

Any Talk of an RMD Waiver for 2022?

"Has there yet been any consideration/action to waive 2022 RMDs (as in years prior), in light of the market plunge in valuations from YE 2021 highs (due to the negative impact on retirement savings)?"

1 reply so far   |    Click Here to Add a Reply

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

Take an In-Service Distribution and Then Roll It Back Over Within 60 Days?

"As we enter into another economically challenging time, I have a business owner who needs money for a short term issue. He wants to, and can, take an in-service distribution, and then return it to the plan within 60 days. I'm thinking he's better off putting it into a new IRA but the advisor is saying to put it back into the plan. What do other piggy bank owners do with such distributions? He understands he'll receive a taxable 1099-R."

1 reply so far   |    Click Here to Add a Reply

TPAnnie created a topic in Relius Administration

Relius ASP -- Customer Service Issues, or Am I Doing Something Wrong?

"Has anyone else been having trouble with Relius ASP customer service? I understand we probably aren't their ideal client, but our issues aren't being resolved.

Problems like posting transactions easily see weeks in turnaround time, and more often than not I'm finding some manual workaround.

Since they've switched to that Portal, though, I'm wondering if I'm going about submitting for help the correct way. It just seems very disjointed for the past year or so.

I'm also unsure that we've gotten any correspondence about the IE discontinuance and how to log in. (I'm using our old standalone version of the software currently because the plans I want to work on don't work on ASP.)"

4 replies so far   |    Click Here to Add a Reply

Rose created a topic in 401(k) Plans

Incorrect ADP Refund to an HCE

"A plan failed the ADP test for the 2020 plan year and a refund was properly issued to the HCE by 12/31/2021. When preparing the 2021 testing, the client discovered some of the compensation reported for 2020 was incorrect. The 2020 ADP test was re-run with the correct compensation and the HCE is now due an additional $184.00. Since we are past the 12 month correction period, will the refund fall under EPCRS and a one-to-one correction required?"

1 reply so far   |    Click Here to Add a Reply

Here are the most recently posted jobs on, a service of BenefitsLink:

View job as Benefits Supervisor

Benefits Supervisor  View details

NFL Player Benefit Office
Baltimore MD

►View More Jobs

►Post a Job

►Get Instant Job Alerts, Inc.
56 Creeksong Road
Whittier NC 28789
(407) 644-4146

Lois Baker, J.D., President
David Rhett Baker, J.D., Editor and Publisher
Holly Horton, Business Manager

Copyright 2022, Inc. All materials contained in this mailing are protected by United States copyright law and may not be reproduced, distributed, transmitted, displayed, published or broadcast without the prior written permission of, Inc., or in the case of third party materials, the owner of those materials. You may not alter or remove any trademark, copyright or other notices from copies of the content.

Links to web sites other than and are offered as a service to our readers; we were not involved in their production and are not responsible for their content.

Unsubscribe | Privacy Policy