Message Boards Digest

February 1, 2023

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

MSN created a topic in 401(k) Plans

On Demand Pay Arrangements & Plan Compensation

"How are TPAs handling on-demand/early-access pay with regard to plan compensation? Is it treated like a traditional payday loan where the employer isn't involved and ignored for plan purposes? Or counted as compensation when the employee has constructive receipt? I want to think it's ignored, but when the program itself is an employer benefit, it feels a little different somehow."

3 replies so far   |    Click Here to Add a Reply

Industry Legend Rich Hochman, J.D. Retires

Sponsored by ASC
It is with mixed emotions that ASC announces the retirement of industry expert and icon Richard Hochman, J.D. “We were very fortunate to have Rich as part of our ASC Team for six years,” says Alan Gould, President of ASC. Read More

Santo Gold created a topic in Plan Terminations

Plan Merger Actually...

"In a plan merger, are the balances of prior terminees also transferred into the new 401k plan? These terminees can take their money out of the original plan at any time. but if they do not and their balance is over $5,000, they have to be rolled into the new plan, is that correct? Thank you"

2 replies so far   |    Click Here to Add a Reply

Tom created a topic in 401(k) Plans

Late Deferral Deposit Correction

"I realize SECURE 2.0 may have changed this possibly. Have a client who hasn't deposited for 4 months in 2022. Dentist bought a practice and didn't know they or their new payroll company needed to initiate payment. The amount for the 4 months is probably less than $5,000. It's being deposited now and I know to report on the 5500 and file Form 5330. My question is the earnings calculation. This will be self-corrected. Can I use the DOL earnings calculator? It is easy to use and takes out any ambiguity. I read different things about whether can be used or not. I'm pretty sure the DOL earnings will be higher than the plan actual earnings for this period (which could even be a loss.)"

2 replies so far   |    Click Here to Add a Reply

austin3515 created a topic in 401(k) Plans

Each in Own Group / No Allocation Conditions

"Plan has no conditions but they exclude people from getting an allocation if they have less than 1,000 hours or term before last day (not top-heavy). But, the plan is now below 70% for coverage. I realize there are Terms with Breaks because last day/1,000 hours is not the 'sole' reason they're not benefitting. But can I use the Average Benefits Test based on the conclusion that excluding people who have less than 1,000 hours or are termed is a reasonable business classification? Follow-up: Does the answer change if I bring one of them in to pass a failed rate group test?"

7 replies so far   |    Click Here to Add a Reply

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