BenefitsLink® Message Boards Digest

November 15, 2023

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

5500sorBust created a topic in Form 5500

Implementing Upcoming Changes to Summary Annual Report

"One of the new items in the SAR model language is the following statement: 'Your plan is a [insert a brief description of the plan based on the plan characteristic codes listed for the plan on the Form 5500, including whether it is a defined contribution or defined benefit plan, and whether the plan is a pooled employer plan, another type of multiple-employer plan or a single-employer plan].' How are you approaching this? Does this mean that we need to list out every individual 5500 characteristic code description (or some version of them) as part of this?"

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FishOn created a topic in SEP, SARSEP and SIMPLE Plans

Simple IRA and Non-Contributing SoloK

"A potential client has a SIMPLE IRA plan for their business. They are continuing the SIMPLE, covering all employees and making the required contributions, but the owner wants to establish a solok and rollover SIMPLE balance into the solok only to take advantage of other investments not offered in the SIMPLE. The owner does not intend to ever make contributions to the solok. The SIMPLE plan has been in existence for more than 2 years. Would this be allowed?"

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Bird created a topic in Retirement Plans in General

Top Heavy Contributions in a Safe Harbor Match Plan

"This is something that came up in the proposal process and probably would never be designed this way, but it's become a curiosity. Let's say you have a SH match plan, and HCEs are excluded from the SHM. But the plan is TH, and Keys (small company so Keys and HCEs are the same) are not excluded from TH. Every NHCE contributes and gets the max SH match. Keys are getting TH (at least in the proposal system) so it winds up that HCEs are getting 3% nonelective and NHCEs get nothing, but the system is showing keys getting 0% nonelective for testing purposes (I guess because it isn't specifically elected as a PS contribution) so it is passing nondiscrimination testing. My take on this is that SH match is deemed to satisfy TH, so the keys should not get a TH contribution. That is, I don't think it is an optional position to say that SH match is deemed to satisfy TH; it does, period. That puts the kibosh on the whole thing, but I still think the TH contributions, if made, should be tested for nondiscrimination (and would fail). Any disagreement on that?"

5 replies so far   |    Click Here to Add a Reply

cathyw created a topic in 457 Plans

Looking for 457(b) Document Provider

"Can someone refer me to a document provider that offers a 457(b) document on a plan-by-plan basis (i.e., not a subscription)? I use ftwilliam for qualified plans but I don't see 457(b) as an offering."

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