"I have a Township who currently offers a 401a plan to it's full time employees. They want to create a plan that offers match, but only for the part time employees -- excluding the individuals who are eligible for the 401a plan. I apologize for my ignorance, but we don't do a ton of these. I think they can do this ... but I would love some confirmation."

"A participant is over age 73 and has an RMD for 2025. He terminated before NRA and because of that, he is not 100% vested. Is the RMD amount calculated based on full account balance or vested account balance?"

"Client is doing a discretionary match of: 100% of deferrals up to 6% of comp up to 5 years of service -- then 150% of deferrals up to 6% of comp if over 5 years of service. 

How the Formula Works (Example: $50,000 Salary)

• Years 1-5:
  • You contribute 6% of $50,000 = $3,000.
  • Employer matches 100% of your contribution up to 6% = $3,000 match.
  • Total contribution: $6,000 ($3,000 your money + $3,000 employer).
• After Year 5:
  • You contribute 6% of $50,000 = $3,000.
  • Employer matches 150% of your contribution up to 6% = $4,500 match.
  • Total contribution: $7,500 ($3,000 your money + $4,500 employer).

Since it relates back to service it can not be used as a safe harbor match. Can they do a Enhanced SH match of 100% of deferrals up to 6% of comp and then a discretionary match of 100% of deferrals up to 3% of comp if you have been then at least 5 years In other words -- 1-5 years 0% match ; 5 years or more 3% match Would that need to be tested alone (ACP) without the safe harbor match? Would ADP test pass automatically since there is a safe harbor match?"

"My new client received a certified letter from a former employee requesting a copy of the SPD from the years in which she was employed (not necessarily a participant), 1997-2003. Since I was not the TPA I don't have the SPD and my client doesn't think he has it either. She was paid a benefit of about $50K in 2005 and apparently is not disputing that. Is my client obligated to provide the old SPD from 23 years ago to the former participant?"

"Question: For the purpose of calculating the top heavy balances, are ADP/ACP corrective distributions added back in? Plan failed 2024 ADP/ACP testing: HCE/Key employees ADP/ACP corrective distributions of $5,000. These were corrected on 3/1/2025. When looking to add back in 'In-Service' distributions, would these be considered that for top heavy balance for the 2025 determination? Or excluded from the Top Heavy balance? My argument is that these distributions were forced distributions because of the failing ADP/ACP test. The participant did not have the option not to take it, so why should it be added back in? Thoughts?"

"A DB plan retiree age is 62. Employee retirement date was March 2025 but did not receive his lump sum until Dec. 2025. He was entitled to his lump sum since March 2025. What rate would you use to give interest on the lump sum from march 25 to Dec 25? Plan equivalence?"