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Message Boards Digest

October 12, 2023

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

pixiebear created a topic in 401(k) Plans

Amending Plan for Discretionary Match

"We have a client who wants to add a discretionary match to their existing 401(k) plan. They want to make the match on a payroll basis and then do a true up at the end of the year. Do they have to adopt the amendment before the first payroll with the match or can they wait to the end of the year?"

1 reply so far   |    Click Here to Add a Reply

Craig Jacobs created a topic in Defined Benefit Plans, Including Cash Balance

417(e) Mortality Table for 2024

"I may have missed it, but has the 417(e) applicable mortality table for 2024 lump sum distributions been published?"

1 reply so far   |    Click Here to Add a Reply

Barbara created a topic in 401(k) Plans

Auto Enrollment Required?

"I have a cross-tested profit sharing plan where the client is considering adding a Safe Harbor 401(k) feature for 2024. Will auto enrollment features be required?"

3 replies so far   |    Click Here to Add a Reply

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

Using 'Corporate' Extension for 5500-SF Filing for NFP?

"I started a new 403b plan for a NFP that was winding down their 401k, and I accidentally used plan number 001 in my document. Of course, the 401k plan is using that number, so I should have used 002. Therefore, 002 was not extended for the 12/31/22 5500-SF.... Isn't there a thing where you can use the corporate extension instead of the 5558? And doesn't an NFP have an initial filing date of 5/15, which then gets extended until at least 10/15? This sounds familiar. Is it available for a NFP?"

2 replies so far   |    Click Here to Add a Reply

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

Terminating DB Plan, Divorced Participant in Pay Status

"Terminating Plan. Participant who has been in pay status for about 25 years, who was divorced sometime after his benefits commenced in the form of a QJSA, and who never informed the Plan that he was divorced, is now complaining about benefit information received from the annuity provider that his former spouse is his joint annuitant as he does not wish his former spouse to receive anything. The divorce occurred after benefits commenced and the participant never notified the plan administrator that he was divorced. Based on current information, the divorce decree did not specifically address pension benefits and no QDRO was entered. The plan does not provide for substitution of a joint annuitant after benefits have commenced. I am leaning towards responding to the participant that his former spouse remains his joint annuitant unless he can provide evidence of a court order that his spouse is not entitled to survivor benefits if he dies before his former spouse, or at least the date and court in which the divorce was granted if there is any obligation for the plan administrator to search for an order."

3 replies so far   |    Click Here to Add a Reply

John Feldt ERPA CPC QPA created a topic in Retirement Plans in General

Projected Limits, COLAs for 2024

"The CPI-U for September 2023 was published with a value of 307.789. Based on Tom Poje's spreadsheet, the dollar limits for 2024 are projected to be: Almost all increased (NOT Official yet, of course): Deferral limit: $23,000 (up from $22,500) Catch-up: $7,500 (unchanged) Compensation Limit: $345,000 (up from $330,000) Annual Addition Limit: $69,000 (up from $66,000) DB Limit: $275,000 (up from $265,000) HCE: $155,000 (up from $150,000) Key Employee: $220,000 (up from $215,000) Just for reference, the unrounded figures are: Catch-up: $7,793.00 Deferral limit: $23,379 Compensation Limit: $345,220 Annual Addition Limit: $69,044 DB Limit: $276,176 HCE: $155,984 Key Employee: $224,393"

3 replies so far   |    Click Here to Add a Reply

Plan Doc created a topic in 457 Plans

Changing Normal Retirement Age Under Governmental 457(b) Plan

"A governmental 457(b) plan that allows employees to designate their normal retirement age wants to establish normal retirement ages of 55 for 'special risk' employees and 65 for all others. Normal retirement age under the plan is meaningful only for purposes of the special 457(b) catch-up. It does not play a role in vesting, as all contributions are 100% immediately vested; waiver of any allocation conditions, as there aren't any; or as a distribution trigger. What limitations, if any, apply to the employer's ability to make this change? For example, would its application be restricted to new participants only?"

1 reply so far   |    Click Here to Add a Reply

Gadgetfreak created a topic in Operating a TPA or Consulting Firm

TPA/Recordkeeper Staffing Structures

"I would be most appreciative if anyone is willing to share some information with me. I am aware of two main staffing structures for TPA firms:

  1. One or more employees are assigned to a block of plans. They handle everything for that plan soup-to-nuts. This is the 'Relationship Manager' approach.
  2. Segregated departments (i.e., conversions, compliance, distributions, etc.).

I believe the former is more prevalent for TPA-only businesses, though I know some TPAs that use the second method. I am more interested in the small to mid-size TPAs that also handle internal daily recordkeeping (say on the Relius, SRT, or Datair daily platform). What structure are you using -- or is it a combination of the above? If I am a new client starting or moving my plan, and you will be handling TPA and recordkeeping, who am I dealing with for implementation and ongoing communications over the entire year? I appreciate any help you can provide."

2 replies so far   |    Click Here to Add a Reply

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