Art of the Qualified Plan Audit

In Summary SECURE Act Changes to RMD Age: The new rules from the SECURE Act raise the age for Required Minimum Distributions (RMDs) from 70½ to 72. Terminated non-5% owners must take their first RMD by April 1 of the year following the later of turning 72 or retiring. Five percent owners must begin RMDs … Continued

In Summary Plan Error Correction Methods in EPCRS: Operational errors in retirement plans can be fixed through the IRS Employee Plans Compliance Resolution System (EPCRS) using the Self-Correction Program (SCP) for certain timely-corrected and insignificant errors, the Voluntary Compliance Program (VCP) with an IRS fee and submission for significant or specific errors, or the Audit … Continued

In Summary Nondiscrimination Tests Limit HCE Contributions: Company owners and highly compensated employees (HCEs) may not contribute the maximum 401(k) limit because of nondiscrimination tests like the ADP and ACP tests. These tests ensure that HCE contributions are not disproportionate and are limited based on the average deferral and match percentages of non-highly compensated employees … Continued

Posted By Maria T. Hurd, CPA, RPA Our first blog about the CARES Act titled Unsaving for Retirement in Pandemic Times discussed the original definition of a Qualifying Individual eligible to take the additional Coronavirus-related loans and distributions. The original definition of a qualified individual applied if the participant in the plan experienced a financial … Continued

Posted by Maria T. Hurd, CPA, RPA For 403(b) plan eligibility determinations, the IRS says that “Once In, Always In” is much better than “In and Out,” so are your part-time employees “In or Out” or “In and Out”? Part-time workers and transient workers have always posed a challenge for plan sponsors trying to determine … Continued

Posted by Maria T. Hurd, CPA, RPA The SECURE Act’s provisions that encourage retirement savings and increase coverage and participation could reduce an estimated retirement savings shortfall of $3.8 trillion dollars by 3%, which does not sound like much percentage-wise, but it amounts to more than one hundred billion dollars: an unquestionably good result.  However, … Continued

Posted By Maria T. Hurd, CPA, RPA Coronavirus-Related Distributions are NOT “Eligible Rollover Distributions,” but They Can be Rolled Over: What Withholding Rate Applies? To address the novel Coronavirus, the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) has created a novel type of distribution from retirement plans: the Coronavirus-Related Distribution (“CRD”). It … Continued

Posted by Maria T. Hurd, CPA, RPA In pandemic times, employer contributions to retirement plans are not immune to cost-cutting initiatives, as corporate cash flows and liquidity dwindle. However, discontinuing discretionary contributions does not always eliminate all employer contribution requirements, and it is important for employers to anticipate and budget for any contributions that cannot … Continued

Posted by Maria T. Hurd, CPA, RPA Every year, retirement plan audit season starts in early April, shortly after discrimination tests are complete and audit packages for the more straightforward plans become available. Human resources managers, payroll managers, and chief financial officers at the plan sponsor collaborate to provide the auditor with payroll, personnel data, … Continued

In Summary Correction Programs Offer Options for RMD Failures: The Employee Plan Compliance Resolution System (EPCRS) provides methods like the Self-Correction Program (SCP) and the Voluntary Correction Program (VCP) for fixing missed RMDs. While VCP allows the plan sponsor to request a waiver of the participant’s excise tax, using the convenient SCP does not automatically … Continued