Message Boards Digest

July 6, 2022

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

AlbanyConsultant created a topic in 401(k) Plans

Lifetime Income Disclosures -- Timing Headaches

"Maybe I'm just realizing this later than everyone else, but because the rates are changing monthly, are we in for a bunch of timing headaches? Specifically....

My efficient assistant prepared the report and statements in April.... and I'm just now getting to reviewing them. It used to not be a big deal because no numbers changed. But now I have to re-run the lifetime income disclosures because the interest rates aren't the same now as they were three months ago (or they might be, maybe.... better not take the chance!).

Let's say I actually did send the statements with disclosures back in April. Plan sponsors being plan sponsors, the package sat on their desk until I reminded them that they actually need to open it and do something, so they don't hand the statements and disclosures out until July. Are the disclosures that we prepared back in April no good? Would the participants ever know or care?

The interest rates are updated near the end of the month (according to the updates I get from my recordkeeping software provider). Does that mean I'm on hold with sending out reports near the end of the month so I don't accidentally force a client to hand out a disclosure notice that is 'behind' by the time they hand it out?

These sound ridiculous.... but that doesn't mean they're not how the rule was written. Of course, then there's 'written' vs. 'interpreted'... anyway, am I working myself up over nothing?"

2 replies so far   |    Click Here to Add a Reply

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CNB CONSULTING created a topic in Retirement Plans in General

Management Group Here Under Section 414(m)(5)?

"Question regarding the management group analysis under 414(m)(5). I have four entities none of which qualify as parent/sub or brother/sister controlled group members. One of the entities definitely provides management functions for the other three, but none of the three recipient organizations provides more than 50% of the gross receipts to the potential management organization.

I know that organizations related to the recipient organization are included as part of the entire group, but I believe that the analysis is scrutinized after the determination of whether a management group even exists. In other words, if I am incorrect and the three recipient entities above were combined prior to the management group analysis is performed, then the combined gross receipts of all of these companies would be above 50% and thus constitute a principal business. I don't think that's the case, but I'd very much like to hear from others."

4 replies so far   |    Click Here to Add a Reply

nancy created a topic in Plan Document Amendments

Any Vendor Have a Money Purchase Plan Document with Option for Mandatory Employee Contributions?

"Does anyone know of a document vendor that has a Money Purchase plan with mandatory employee contributions (not a governmental plan)."

No replies yet   |    Click Here to Add a Reply

David Peckham created a topic in Retirement Plans in General

Can the Cycle 3 Plan Restatement Fee Be Paid from Plan Assets?

"Is a mandatory plan restatement (for example, a Cycle 3 restatement) considered a settlor function by the DOL? Or can the fee be paid from plan assets?"

4 replies so far   |    Click Here to Add a Reply

M Norton created a topic in 401(k) Plans

Safe Harbor Match Not Deposited for 2020

"Small SH 401(k) plan (one M.D., six NHCEs) had balance due for 2020 Safe Harbor match. As of mid-2022, the 2020 SH match had not been deposited to plan (pooled accounts). What options does the plan sponsor have to correct this?"

1 reply so far   |    Click Here to Add a Reply

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