We are pleased to announce our recent hiring of Mark Fishbein, QPA, QKA, ERPA.
Prior to joining our firm, Mark was a partner at Pension Planning Concepts in West Hartford where he specialized in consulting and administration of retirement plans and served as the firm’s senior consultant.
Mark comes to us with significant expertise in all aspects of pension administration as well as experience in design, implementation, consulting and evaluation of all qualified retirement plans.
Mark’s experience will be a tremendous asset to our firm and we look forward to having him work with us and continue our commitment to provide quality, reliable, consistent, and personalized service to our clients.
He joins the rest of our team which now stands at 25 with offices in Farmington and Stamford, CT.
The following information applies solely to those clients who have adopted a PASI, LLC plan document for a 401(k) or a Profit Sharing Plan. If your Plan is drafted by an attorney, a different set of rules applies.
Some of you may recall that during the period from 2008 through 2010, all qualified plans utilizing a “pre-approved” plan document (such as the one distributed by PASI) were required to restate that plan in its entirety. We are at the opening once again of this six year cycle and as such plan sponsors must adopt these new “PPA Restatements” between May 1, 2014 and April 30, 2016.
These newly restated plan documents serve two purposes:
- In lieu of having the effects of new legislation and regulation incorporated into the plan via cumbersome amendments/attachments, the effects thereof are incorporated into the body of the plan document.
- It allows our document provider to incorporate new provisions into the Plan that make it easier for us to meet your objectives. To the extent that these new options will benefit you, we will be proactive in contacting you for consideration.
PASI will be preparing these plan restatements over the next 2 years and will contact you when they are ready for execution. As with the previous restatement cycle, you will be receiving more detailed information on how this will effect your plan.
Important Update – Safe Harbor Plans
The following relates to “Safe Harbor Plans” that include other employer contribution balances that are subject to a vesting schedule, such as profit sharing contributions or “regular” matching contributions.
The most controversial change insisted upon by the IRS (despite substantial lobbying efforts) deals with using forfeitures (in lieu of cash deposits) to fund any part of a Safe Harbor Contribution. This change is derived from a new interpretation of an old rule. In summary, the IRS is relying on the following excerpt from the Internal Revenue Code:
“[when] employer contributions [are] made to the trust …[they must be] nonforfeitable”
PASI’s current IRS approved document (i.e., the one that will be phased out over the next two years) explicitly permits forfeitures to be used to offset safe harbor contributions. As such, this matter will only be applicable after your Plan has been restated. PASI will coordinate the timing of this amendment with you based on your individual facts and circumstances. This provision can be delayed until 2017.
At such time as these new provisions become effective, the following options to dispose of forfeitures remain (any or all may apply):
- Utilize the forfeitures towards plan expenses, such as administration (i.e., PASI), recordkeeping, or your CPA Audit (if required).
- Offset other employer contributions that might be allocated.
- Allocate these forfeitures as additional employer contributions. The out-of-pocket cost to the employer is increased as a result of this change.
Choosing PASI Payroll can reduce your administrative burdens, and minimize errors and delays that often occur with separate vendors managing your retirement planning and payroll activities.
You can get ease of payroll, and save money when you choose PASI’s state-of-the-art payroll technology. It’s a package of complete, accurate and affordable payroll services that also allow you to realize full integration and custom reports. Plus, you eliminate the need for compiling year-end Census data!
Call us or visit our website for more information about our Payroll Services.