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October 1, 2024

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

Gilmore created a topic in 401(k) Plans

Increased Catch-Up in 2025: Mandatory or Optional?

"Do we know for certain if the increased catch-up limit for ages 60 through 63 is mandatory if a plan allows catch-up contributions, or is the increased limit optional so the same catch-up limit could continue apply to all catch-up eligible as in pre-2025 if the plan wishes to do so? I've seen what I thought was a reliable source indicate that the change appears mandatory if the plan offers catch-up, but more guidance is required. I've also just received information from a recordkeeper that is indicating the decision to have catch-up and not have the increased limits is optional."

1 reply so far   |    Click Here to Add a Reply

DR245 created a topic in Defined Benefit Plans, Including Cash Balance

Participant Question: ERISA Section 204(h) Notice - Seriousness and Options Available?

"A bunch of employees at our company received this notice on 8/16/24. None of us were aware that we were part of this program. To this date, we have not been told anything else or status of what is going on. What are some of the appropriate options we should be considering? Just merely wait and see? Meanwhile, I am one of the employees that was ultimately terminated on 9/27/24, due to cost cutting measures, directly/indirectly tied to this debacle that has apparently caused financial hardship to the 'Company'." [Text of notice included in the message board post.]

2 replies so far   |    Click Here to Add a Reply

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

How Is the Maximum Defined Benefit Calculated for Older NRA's Like Ages NRA 70 or NRA 85?

"How is the maximum Defined Benefit calculated for older NRA's like ages NRA 70 or NRA 85?"

2 replies so far   |    Click Here to Add a Reply

RayJJohnsonJr created a topic in Form 5500

Can We File 5500-EZ?

"A CPA asks me, If I have a small business with a DB Plan, 3 owners, no employees. Can they file 5500EZ?"

2 replies so far   |    Click Here to Add a Reply

Peter Gulia created a topic in 401(k) Plans

Does a Recordkeeper Inform a Plan Sponsor About the Long-Term-Part-Time Provision?

"Tax law's remedial-amendment regime often involves a few years' lags between when a plan's administrator implements a provision 'in operation' and when the provision is expressed in the plan's document, often an IRS-preapproved document. For optional changes, recordkeepers seem to get a sponsor/administrator's instructions -- yes or no, this-way or that-way, even if many of these are obtained using implied-assent presumptions. But what about a required change? If there is yet no document for a plan's sponsor/administrator to sign or accept (and no choice that need be made), does a recordkeeper inform its customer about a plan provision that changes because ERISA commands it or tax law requires it as a condition of the plan's tax-qualified treatment?

"Imagine a plan sponsor has no lawyer, no third-party administrator, no adviser; only the recordkeeper. Would such a sponsor/administrator know that it must ignore an exclusion the plan document states (and typically the summary plan description explains) to make eligible for elective deferrals those of its employees who meet the long-term-part-time conditions? What have recordkeepers been doing? Does a recordkeeper inform plan sponsors? If so, how much does a recordkeeper explain about the long-term-part-time provision?"

3 replies so far   |    Click Here to Add a Reply

Belgarath created a topic in Retirement Plans in General

Disaster Relief: 404(a)(6) Deadline

"With all the disasters going on, I'd like to confirm the following scenario. This seems straightforward to me, which always scares the heck out of me and makes me assume I'm missing something. Suppose a client is in an officially presidentially declared disaster area. Client had already obtained an extension to October 15. The disaster declaration postpones the business tax filing deadline to (whatever date.) Plan is not a pension plan subject to minimum filing deadlines. Since 404(a)(6) allows a contribution and deduction for prior year if done by the tax filing deadline, including extensions, then the disaster filing extension presumably also extends the CONTRIBUTION deadline, and not just the actual filing of the business tax return?"

2 replies so far   |    Click Here to Add a Reply

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