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September 10, 2024

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

erisageek1978 created a topic in 403(b) Plans, Accounts or Annuities

Can Employer Limit 403(b) Contributions to Employees Employed on Date of Contribution?

"Employer wants to limit contributions to situations only if employee is employed on date of contribution. Currently, employee vests in a contribution and then the contribution is made let's say 1 month after the vesting date. Employer wants to amend plan so that if the employee is not employed on date of contribution, then they don't get the contribution. Is that even permissible ?"

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alwaysaquestion created a topic in 401(k) Plans

Salary Deferral Contribution Timing

"This plan is 401(k), there are 4 participants 2 hce and 2 nhce's. Have a corporate ext receive earned income. I am working on the 12/31/2023 plan year end. Do the hce's have until the due date of their corporate return 9/15/2024 to make their salary deferral contribution for the 12/31/2023 plan year end?"

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alwaysaquestion created a topic in 401(k) Plans

Participant Benefit Statements

"How often does a plan need to provide a participant statement in a 401(k) Plan? The money is all in a brokerage account (pooled)"

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Grace2024 created a topic in Health Plans (Including ACA, COBRA, HIPAA)

Considering Selling TPA

"I am considering selling my TPA business. The vast majority of the business income is derived from administering self-funded group health plans. Has anyone been through the process recently and know how long the transaction can take and how much the 'going rate' is for a book of business sale?"

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Jeff G. created a topic in Retirement Plans in General

Controlled Group Rules in Year of Business Sale

"Married clients own two companies in a controlled group, business 'A' with W-2 employees and business 'B' with only spousal employees (real estate holding company with s-corp election). Neither company offered a retirement plan. Business A has been sold effective 9/1/24. If Business B were to create a solo 401k plan with a 10/1 adoption date, would controlled group rules still apply for the remainder of 2024 tax year?"

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youngbenefitslawyer created a topic in Cafeteria Plans

QMCSO Rescinded: Qualifying Life Event?

"Is it permissible for an employee to cancel his coverage when he enrolled solely because a court issued a QMCSO requiring him to cover his dependent and such order was subsequently rescinded? Employee was not previously enrolled and had to enroll for coverage to comply with the original order to cover the child."

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Peter Gulia created a topic in Correction of Plan Defects

Must an Employer's Payroll Impose a During-The-Year Cutoff on Elective Deferrals?

"In 2025, a particular participant's limit on elective deferrals might involve four (or more) variations, turning with the participant's age (0-49, 50-59, 60-63, 64+). Some employers might try, in payroll, to impose a during-the-year cutoff on Section 401(k), Section 403(b), or Section 457(b) elective deferrals. But some employers might lack software or other ways to impose such a cutoff reliably. For some, imposing an unnuanced cutoff could deprive a 60-63 participant or even participants older than 49 of what might be a legitimate elective deferral.

"How important is it to apply a cutoff during a year? Or is it good enough that each January an employer checks the recently closed year's sum of amounts paid over for elective deferrals to find each individual with an excess and instruct a corrective distribution? In which situations would an excess deferral not be corrected by a corrective distribution or by W-2 reporting?"

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