An employee we just hired wants to roll-over his retirement account from his previous employer’s Plan, but he’s hasn’t satisfied our Plan’s minimum service requirement. Must he/she wait?
No. It is an acceptable practice for Trustee(s) to accept qualified rollovers in advance of participation.
Is there a form to rollover an account from a previous employer’s Plan?
All paperwork is generally between the employee and the Plan Administrator of the prior Plan. He/she will need to provide the exact name of the new Plan and mailing instructions. Recent legislative changes have limited the liability to the Plan of accepting rollover monies from Plans that become disqualified.
What is the “Summary Annual Report” (SAR) that I need to provide to participants?
The SAR is the one or two page plain-English summary of the annual 5500 series report and contains the following information: name, address and federal identification number of the Plan; participant count; a summary of plan income and expenses and beginning and ending trust balances. Since the 5500 forms become public record, there is no sensitive or confidential information divulged. The SAR is not to be confused with the (Employer’s) annual report.
I am unable to answer one of our participant’s questions. Can I have him/her call our administrator at PPP?
No. We do not correspond directly to plan participants. We have found that it works best if we have a single contact at the sponsor for the flow of information.
I just received the annual 5500 booklet from the IRS, should I forward these to PPP, Inc.?
No. Our administration software generates the forms on our printers.
What is the surety bond?
Federal regulations require non-institutional Trustees to be bonded for at least 10% of Plan assets. Each Trustee and the name of the Plan must be included in the coverage, which is typically obtained from business/casualty providers.
A terminated Plan participant has been rehired. Must he/she wait to satisfy the eligibility requirements from the rehire date before rejoining the Plan?
Generally no; if the break in service was less than five years, the employee rejoins the Plan immediately upon rehire. Furthermore, the employee has the right to buyback from the Plan nonvested forfeitures from an earlier distribution by repaying the employer-derived portion of that distribution.
Why do I need to report part-time employees to you?
Part-time is a relative term. The conditions for becoming a participant in the Plan are specifically addressed in the Plan document, as required by law.
Do I need to fill out the forms you sent us requesting census information?
Internal or payroll company generated reports that provide the same information being requested is always acceptable.
Someone just had their first employment anniversary. Since our plan has a 12 month waiting period, can he/she start 401(k) contributions immediately?
Not necessarily. Most plans are written with a limited number of plan entry dates during the year, such as the first day of the month or calendar quarter. Many more plans have only 2 or even 1 entry dates during any year. It is important to identify newly eligible employees and have them enrolled into the plan at each of the defined entry dates (and not before!).
Why do I sign the 5500 as Plan Administrator? I thought PPP was Plan Administrator?
PPP is retained by the sponsor to assist them in the administrative/compliance aspects of running their plans. The “Capital P”, “Capital A” Plan Administrator is a plan fiduciary who has authority over the operation of the plan, including outsourcing of the vendors/service providers engaged, and the decision to adopt and continue sponsorship of the retirement program.
Why does the employer information form ask if we’re making a profit sharing contribution when we actually have a 401(k) Plan?
Most 401(k) Plans provide for this optional additional company contribution that can be made after the plan year ends and used to reduce a sponsor’s taxable income for the fiscal year.
How do I change a participant’s address for statements?
PPP, Inc. does not do any direct mailing to plan participants; therefore, it is most appropriate to contact the Recordkeeper (investment company) directly.