Transcription of Terminating 401(k) and Other Defined Contribution Plans
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Terminating 401(k) and Other Defined Contribution Plans
Terminating 401(k) andOther Defined Contribution PlansWilliam C. Grossman, ERPA, QPA, APAWCG ERISA CONSULTING, LLCE-mail: Valid Business Reason for termination termination Date and Documentation Participant Notification Requirements plan Amendments Determination Letter Apply or Not? 5500 Reporting Final Year Compliance Testing Final contributions /Allocations2 Agenda Vesting Distribution of Assets Successor- plan Rules Abandoned- plan Rules Partial termination Deemed termination MEP Terminations Recap of termination Requirements3 termination Date and DocumentationDefined Contribution termination Date and Documentation DC determination of when the plan terminates based on all the facts and circumstances as ERISA 4041 not applicable Cite: Treas. Reg. (d)-2(c)(3) & (b) Usually, a resolution adopted by the employer is sufficientto establish the termination date ( , board resolution adopted by the board of directors of a corporate plan sponsor)5 Defined Contribution termination Date and Documentation For DC pension Plans , such as money purchase plan or target benefit Plans , the termination date is not effective before the ERISA 204(h) notice requirements are satisfied Unless plan is not subject to Title I of ERISA For pension Plans frozen prior to their termination , provided the ERISA 204(h) notice was given at that time, then a resolution Terminating the plan is sufficient to establish the termination date6 termination Documenta
Apr 04, 2017 · • Plan name, plan ID number, plan administrator name • Name and TIN of the applicant • Statement that an application for a determination on the qualified status of the plan is being made to the IRS for a plan termination 23
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