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Dual-Status Hospitals and Retirement Plans

“One of my plan sponsor clients is a hospital that has dual status as a tax-exempt entity and a governmental entity. Could the dual-status hospital have both a 403(b) plan and a 457(b) plan?

ERISA consultants at the Retirement Learning Center Resource Desk regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings and income plans, including nonqualified plans, stock options, and Social Security and Medicare.  We bring Case of the Week to you to highlight the most relevant topics affecting your business.

A recent call with an advisor in Colorado is representative of a common inquiry regarding governmental and tax-exempt entities.

Highlights of Discussion

Dual-status entities could include governmental hospital organizations that have received a determination letter from the IRS stating it is exempt from taxes under IRC Sec. 501(c)(3) and that it also qualifies as an affiliate of a government unit as described in Rev. Proc. 95-48.

Yes, a governmental entity that also satisfies the requirements of IRC Sec. 501(c)(3) (i.e., a dual-status entity) may maintain both a 403(b) plan and a 457(b) plan. This was affirmed in the preamble to the proposed 403(b) regulations (see page 67078 of REG–155608–02).

“Under sections 457(b)(6) and 457(g), an entity that is both an instrumentality of a State and a section 501(c)(3) organization can have an eligible plan under section 457(b) only if it is funded. However, under section 403(b)(1)(A)(i) and (ii), an entity that is both an instrumentality of a State and a section 501(c)(3) organization could cover any of its employees, regardless of whether they are performing services for a public school.”

That means, any employee that is eligible to participate in both the 403(b) plan and the 457(b) plan would have two separate deferral limits and, potentially, would be able to essentially “double up” on elective deferral contributions (See PLR-145997-08). The Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA), effective after December 31, 2001, no longer imposes any requirement to reduce the maximum amount that an individual may defer under a 457(b) plan by any amount contributed for such individual to a different type of deferral plan such as a 403(b) plan.

A word of caution:  It is important for a dual-status hospital to make sure it satisfies the requirements of IRC Sec. 501(r)(1) as well as  Revenue Ruling 69-545. In recent years, the IRS has revoked a hospital’s tax-exempt status under IRC Sec. 501(c) for failing to comply with IRC Sec. 501(r)(1) (PLR 201829017). For more information see Charitable Hospitals – General Requirements for Tax-Exemption Under Section 501(c)(3).

Conclusion

It is possible for a governmental entity that also satisfies the requirements of IRC Sec. 501(c)(3) (i.e., a dual-status entity) to maintain both a 403(b) plan and a 457(b) plan.

 

 

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Designated Roth Account Rollover and Five-Year Rule

“My client participates in a 401(k) plan, has a Designated Roth account and wants to roll over the Designated Roth account to a Roth IRA. Can my client count the time in the 401(k) plan towards the five-year waiting period for the Roth IRA needed for taking qualified distributions?”

ERISA consultants at the Retirement Learning Center Resource Desk regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings and income plans, including nonqualified plans, stock options, and Social Security and Medicare. We bring Case of the Week to you to highlight the most relevant topics affecting your business.

A recent call with an advisor in Pennsylvania is representative of a common inquiry regarding Designated Roth contributions in a 401(k) plan.

Highlights of Discussion
The short answer is, surprisingly, “No.” If your client rolls over his or her 401(k) plan Designated Roth account assets to a Roth IRA, the time spent in the Designated Roth account will not carry over to the Roth IRA (IRS Treasury Regulation § 1.408A–10, Q&A 4).

That means, if your client established his or her first Roth IRA with the rollover of Designated Roth account assets, the five-year period for determining qualified distributions from the Roth IRA would begin that year. In essence, the five-year period for determining qualified distributions in the 401(k) plan is determined separately from the five-year period for determining qualified distributions in the Roth IRA.

It’s another one of those “earlier of” scenarios for the Roth IRA and the five-year period §1.408A–6, Q&A 2. The five-year period for the Roth IRA begins with the earlier of the taxable year in which

• The first Roth IRA contribution (or conversion) is made to any Roth IRA owned by the individual, or
• A rollover contribution of a Designated Roth account is made to a Roth IRA.

Conclusion
The five-year period for determining qualified distributions from a 401(k) plan Designated Roth account is determined separately from the five-year period for determining qualified distributions in a Roth IRA. For that reason, it may be advantageous for investors to make a Roth IRA contribution sooner rather than later in order to put the five-year clock in motion in the Roth IRA.

 

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Remember the Saver’s Tax Credit

“Can you remind me of the special tax credit available for individuals who make retirement savings contributions, please?”

ERISA consultants at the Retirement Learning Center Resource Desk regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings and income plans, including nonqualified plans, stock options, and Social Security and Medicare.  We bring Case of the Week to you to highlight the most relevant topics affecting your business.

A recent call with an advisor in Nevada is representative of a common inquiry regarding available tax credits for personal contributions to eligible plans.

Highlights of Discussion

Absolutely, after all, it is tax time! IRA owners, retirement plan participants (including self-employed individuals) and others may qualify for the IRS’s “Saver’s Credit” for certain contributions made to eligible savings arrangements. Details of the credit appear in IRS Publication 590-A and here Saver’s Credit.

The credit

  • Equals an amount up to 50%, 20% or 10% of eligible taxpayer contributions up to $2,000 ($4,000 if married filing jointly), depending on adjusted gross income (as reported on Form 1040, 1040SR or 1040NR);
  • Relates to contributions taxpayers make to their traditional and/or Roth IRAs, or elective deferrals to a 401(k) or similar workplace retirement plan (other plans qualify so see full list below); and
  • Is claimed by a taxpayer on Form 8880, Credit for Qualified Retirement Savings Contributions.

Contributors can claim the Saver’s Credit for personal contributions (including voluntary after-tax contributions) made to

  • A traditional or Roth IRA;
  • 401(k),
  • Savings Incentive Match Plan for Employees (SIMPLE) IRA,
  • Salary Reduction Simplified Employee Pension (SARSEP),
  • 403(b),
  • Governmental 457(b),
  • Federal Thrift Savings Plan,
  • ABLE account* or
  • Tax-exempt, union pension benefit plan under IRC Sec. 501(c)(18)(D).

In general, the contribution tax credit is available to individuals who

1) Are age 18 or older;

2) Not a full-time student;

3) Not claimed as a dependent on another person’s return; and

4) Have income below a certain level (see table that follows).

* The Achieving a Better Life Experience (ABLE) Act of 2014 allows states to create tax-advantaged savings programs for eligible people with disabilities (designated beneficiaries). Funds from ABLE accounts can help designated beneficiaries pay for qualified disability expenses on a tax-free basis.

2021 Saver’s Credit Income Levels

Credit Rate Married Filing Jointly Head of Household All Other Filers*
50% of your contribution AGI not more than $39,500 AGI not more than $29,625 AGI not more than $19,750
20% of your contribution $39,501 – $43,000 $29,626 – $32,250 $19,751 – $21,500
10% of your contribution $43,001 – $66,000 $32,251 – $49,500 $21,501 – $33,000
0% of your contribution More than $66,000 More than $49,500 More than $33,000

*Single, married filing separately, or qualifying widow(er)

The IRS has a handy on-line “interview” that taxpayers may use to determine whether they are eligible for the credit.

Conclusion

Every deduction and tax credit counts these days. Many IRA owners and plan participants may be unaware of the retirement plan-related tax credits for which they may qualify.

 

 

 

 

 

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“I’m confused about the deadlines for correcting 401(k) plan excesses. Can you give me quick tutorial?”

ERISA consultants at the Retirement Learning Center Resource Desk regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings and income plans, including nonqualified plans, stock options, and Social Security and Medicare.  We bring Case of the Week to you to highlight the most relevant topics affecting your business.

A recent call with an advisor in Minnesota is representative of a common inquiry regarding 401(k) plan nondiscrimination testing.

Highlights of Discussion

I’ll try my best to summarize, generally, but be sure to seek out tax and/or legal advice for actual plan situations. One of the characteristics that sets 401(k) plans apart from other defined contribution plans are the unique contribution limits that apply to employee salary deferrals and matching contributions, namely the actual deferral percentage (ADP) limit, the actual contribution percentage (ACP) limit, and the IRC Sec. 402(g) annual deferral limit.

I’ll cover the three following excesses in this space:

  1. ADP failures—where the highly compensated employees (HCEs) defer too much in relation to the nonHCEs and create “excess contributions” [IRC Sec. 401(k)(8)(b)]
  2. ACP failures—where matching and/or after-tax contributions are too high for HCEs in relation to those for nonHCEs and create “excess aggregate contributions” [IRC Sec. 401(m)(6)(B)]
  3. 402(g) failures—where plan participants, either HCEs or nonHCEs, defer above the annual limit and create “excess deferrals” [IRC Sec. 402(g)(3)]
401(k) Excess Correction Deadlines
Type of 401(k) Excess Time of Correction Consequences of Failing to Timely Correct
Excess Contributions (ADP test failure where HCEs defer too much compared to nonHCEs)

 

Or

 

Excess Aggregate Contributions (ACP test failure where HCEs’ matching and or after-tax contributions are too high compared to nonHCEs’)

 

Within 2½ months after plan year end (March 15th for a calendar year plan)

Issue corrective distributions to affected HCEs

 

 

 

Excess and earnings taxed in the year distributed

 

 

After 2 ½ months after plan year end

 

Two Corrective Options:

1. Issue corrective distributions to HCEs

or

2. Make a Qualified Nonelective Contribution/Qualified Matching Contribution to correct the failure

·     Excess and earnings taxed in the year distributed

·     Employer subject to a 10% penalty tax

After the end of the plan year following the year of the excess

 

·   Employer subject to a 10% penalty tax

·   Potential for plan disqualification

·   Correct through Employee Plans Compliance Resolution System (EPCRS)

 

If “eligible automatic contribution arrangement” Excess Contribution or Excess Aggregate Contribution

 

6 months following the end of the plan year (June 30 for calendar year plan)

 

Issue corrective distributions to affected HCEs

 

Excess and earnings taxed in the year distributed
After 6 months following the end of the plan year

 

Two Corrective Options:

 

1. Issue corrective distributions to HCEs or

2. Make a Qualified Nonelective Contribution/Qualified Matching Contribution to correct the failure

·   Excess and earnings taxed in the year distributed

 

·   Employer subject to additional 10% penalty tax

 

After the end of the plan year following the year of excess (December 31 for calendar year plan)

 

·      Employer subject to additional 10% penalty tax

·      Potential for plan disqualification

·      Correct through EPCRS

 

Excess Deferrals (402(g) failure, Pre-Tax and Designated Roth) On or before April 15th of year after deferral

Issue corrective distributions of excess deferrals, plus their earnings

·      Excess deferral taxed as income in the year deferred.

·      Earnings on excess taxed in the year distributed.

After April 15 of year following excess

 

·   Excess deferral taxed in the year deferred.

·   Both the excess deferral and earnings taxed in the year removed.

·   If excess deferrals result from deferrals to one or more plans maintained by the same employer, possible loss of qualified plan status

 

Amounts in excess of any one of these limits could have serious consequences for the employer, the participant and/or the plan as a whole. Plan penalties are costly to plan sponsors and every effort should be made to avoid them. But worse than paying the IRS an extra penalty fee is the potential loss of qualified status for the 401(k) plan. If the IRS disqualifies a plan, the plan sponsor loses the tax-saving benefits of the plan, and the assets become immediately taxable to the participants. Therefore, such excesses must be avoided and timely corrected when failures occur.

Conclusion

Treasury regulations contain clear steps and deadlines by which plan sponsors must correct 401(k) excesses. If done so timely, the plan sponsor can avoid additional penalties and potential plan disqualification. Corrections made after the specified deadlines must follow the terms of the IRS’s EPCRS.

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DOL Enforcement Deadlines for PTE 2020-02

An advisor asked: “I’m confused by the compliance deadlines for various provisions of Prohibited Transaction Exemption (PTE) 2020-02 related to providing investment advice to retirement investors.  Can you summarize the enforcement deadlines, please?”

Highlights of Discussion

Absolutely; financial professionals and institutions that seek to comply with PTE 2020-02 must satisfy the following six steps by the dates indicated.

PTE 2020-02 Requirements DOL Enforcement Begins
1. Provide advice in accordance with the three “Impartial Conduct Standards,” which mandate that advice be given

·         In the best interest of the retirement investor,

·         At a reasonable price,

·         Without any misleading statements.

 

After January 31, 2022

 

Originally effective February 16, 2021, the DOL implemented a “nonenforcement policy” under DOL FAB 2018-02 Field Assistance Bulletin (FAB) 2018-02 until December 20, 2021, for those who diligently and in good faith complied with the Impartial Conduct Standards. FAB 2021-02  further extended the nonenforcement policy through January 31, 2022.

 

2. Acknowledge in writing their fiduciary status under ERISA and the Internal Revenue Code;

3. Describe in writing the services to be provided and any material conflicts of interest that may exist;

4. Adopt policies and procedures prudently designed to ensure compliance with the Impartial Conduct Standards and that mitigate conflicts of interest;

5.     Conduct an annual retrospective review of their compliance with the requirements and produce a written report that is certified by one of the financial institution’s senior executive officers;

After January 31, 2022

 

Pursuant to FAB 2021-02, the DOL will not pursue cases against advisors and institutions utilizing PTE 2020-02, provided they make a good faith effort to follow the three Impartial Conduct Standards (see #1 above)

6. FOR ROLLOVERS:  If the advice involves a rollover recommendation, then

 

• Document the reasons that a rollover recommendation is in the best interest of the retirement investor; and

 

• Disclose the justification for the rollover in writing to the retirement investor.

After June 30, 2022

 

Pursuant to FAB 2021-02, the DOL will not enforce the rollover documentation and disclosure requirements of PTE through June 30, 2022.

Conclusion

Financial professionals and organizations that seek relief under PTE 2020-02 should take note of the different enforcement deadlines that apply as a result of FAB 2021-02.

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Remember Plan Tax Credits for 2021

“Can you remind me of the special tax credits available for small businesses who set up qualified retirement plans, please?”

ERISA consultants at the Retirement Learning Center (RLC) Resource Desk regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings and income plans, including nonqualified plans, stock options, and Social Security and Medicare. We bring Case of the Week to you to highlight the most relevant topics affecting your business.

A recent call with a financial advisor from Arizona is representative of a common inquiry related to incentives for setting up retirement plans.

Highlights of Discussion

My pleasure! Small business owners (with fewer than 100 employees) are eligible for additional tax credits for setting-up retirement plans and/or adding an automatic enrollment feature. The credits are available if the owner establishes a 401(k), a SEP or a SIMPLE IRA plan. The business must

• Have had fewer than 100 employees who received at least $5,000 in compensation for the preceding year;
• Have at least one plan participant who was a nonhighly compensated employee; and
• Not have maintained a plan in the past.

The “Startup Credit” is up to $5,000 (a formula applies), available for the first three years the plan is in existence and offers real benefits to owners by freeing up tax dollars for other important business purposes. The credit was greatly improved as part of the Setting Every Community Up for Retirement Enhancement of 2019 Act (SECURE Act), effective January 1, 2020 (increasing the maximum credit from $500 to $5,000). It is intended to encourage owners to establish retirement plans by helping make the plan more affordable during the startup process. In addition, the owners receive full tax deductions for all contributions made to the plan.

On top of that, if an owner elects to add an automatic enrollment feature to the plan, an additional $500 credit (for the first three years) is also available. The automatic enrollment feature calls for newly eligible participants to be enrolled automatically in the plan with a specified default deferral rate. The IRS provides additional details about the startup and auto deferral credits here.

Eligible businesses may claim the credit using Form 8881, Credit for Small Employer Pension Plan Startup Costs.

See the Instructions for Form 8881 for more details.

Conclusion
Tax credits for setting up a plan and having an automatic enrollment feature are great tools to help small businesses defray the initial costs of starting and maintaining a plan. Business owners should discuss the credits with their accountants and advisors to determine if it makes sense for them to establish a plan.

 

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EINs for Qualified Retirement Plan Trusts

“Can a business owner use the company’s employer identification number (EIN) to identify the firm’s 401(k)?”

ERISA consultants at the Retirement Learning Center (RLC) Resource Desk regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings and income plans, including nonqualified plans, stock options, and Social Security and Medicare.  We bring Case of the Week to you to highlight the most relevant topics affecting your business.

A recent call with a financial advisor from Florida is representative of a common inquiry related to qualified retirement plan trusts.

Highlights of Discussion

No, it is not recommended that a company use the same EIN number for the retirement plan trust as it uses for the business. An EIN is a 9-digit number (for example, 12-3456789) assigned to sole proprietors, corporations, partnerships, estates, trusts, and other entities for tax filing and reporting purposes. The business and the qualified plan trust are separate legal tax entities in the eyes of the IRS; therefore, each needs its own EIN.

To obtain an EIN for a retirement plan trust, the plan trustee can either apply online, mail or fax a copy of Form SS-4, Application for Employer Identification Number to the IRS.[1]  For additional details on the process, please see the IRS’s post How to Obtain or Re-Establish an EIN for a Retirement Plan Trust.  The Instructions for Form SS-4 explain how to complete the SS-4 when seeking an EIN for a qualified plan trust.  Additional information on EIN’s for retirement plans in contained in IRS Publication 1635, Employer Identification Number.

Conclusion

The IRS is clear that it wants qualified retirement plans—even for plans for owner-only businesses—to use a separate EIN for plan reporting purposes.

[1] Instructions for Form SS-4

 

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Group of Plans or Defined Contribution Group Plans

“Are there any new plan types for 2022?”

ERISA consultants at the Retirement Learning Center (RLC) Resource Desk regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings and income plans, including nonqualified plans, stock options, and Social Security and Medicare. We bring Case of the Week to you to highlight the most relevant topics affecting your business.

A recent call with a financial advisor from New York is representative of a common inquiry related to types of retirement plans. The advisor asked: “Are there any new plan types for 2022?”

Highlights of Discussion

Yes, there is. Thanks to The Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019, Pub. L. 116–94, effective for the 2022 plan year the industry now has Groups of Plans (GoPs) (a.k.a., Defined Contribution Group Plans). Technically, it is a simplified mechanism for filing a single Form 5500 information return for a collection of defined contribution plans that have the same

• Trustee,
• Named fiduciary (or named fiduciaries),
• Plan administrator,
• Plan year, and
• Investment options.

If you are thinking Multiple Employer Plan (MEP) or Pooled Employer Plan (PEP), think again. Generally, MEPs and PEPs allow more than one employer to participate in a single retirement plan. In contrast, GoPs allow several employers each with their own defined contribution plan to file a single Form 5500 for the collection of plans, if they have the same trustee, named fiduciary, administrator, plan year and investment options.

While the industry received some information on GoPs in the Department of Labor’s (DOL) proposed Form 5500 changes released in September 2021, more was anticipated in the DOL’s final Form 5500 regulations and news release issued December 29, 2021. Unfortunately, none was present—just a promise that the consolidated filing option for certain groups of defined contribution retirement plans would be the subject of one or more later final notices.

Conclusion
The SECURE Act created a consolidated Form 5500 filing option for GoPs beginning with the 2022 plan year. The devil is in the details, as they say, and the industry anxiously awaits them.

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Governmental 457(b) Plans and Corrections

 “Are there any guidelines for correcting governmental 457(b) plan errors?” 

ERISA consultants at the Retirement Learning Center (RLC) Resource Desk regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings and income plans, including nonqualified plans, stock options, and Social Security and Medicare.  We bring Case of the Week to you to highlight the most relevant topics affecting your business.

A recent call with a financial advisor from Pennsylvania is representative of a common inquiry related to correcting governmental 457(b) plan errors.

Highlights of Discussion

Yes, there are.  The IRS gives a great deal of leeway to governmental 457 plans to self-correct many errors following the guidelines in its Employee Plans Compliance Resolution System (EPCRS) contained in Revenue Procedure 2021-30.

For a general summary, please see the IRS’s website guidance 457(b) Plan Submissions to Voluntary Compliance.  Note the section on “Governmental plan sponsors can self-correct.”  There is no IRS filing or fee associated with self correction, but the sponsoring entity should maintain adequate records to demonstrate it properly corrected the error in the event of a plan audit.

Here are the basics steps to self correction:

  1. Make any necessary corrections to put the participants in the position they would have been in if the error had not occurred.
  2. Document the steps you took to correct the error.
  3. Adjust your administrative procedures, if necessary, to make sure the mistake does not happen again.

Any reasonable and appropriate self-correction method described in Section 6 of EPCRS may be used.

Conclusion

The IRS has included correction principles in its EPCRS for 457(b) plan sponsors.  Governmental 457(b) plan sponsors have the added ability to self-correct many errors.

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401(k) Plans, Distributions and Spousal Consent

 “Do 401(k) plans require the spouse of a plan participant to consent to a plan distribution?” 

ERISA consultants at the Retirement Learning Center (RLC) Resource Desk regularly receive calls from financial advisors on a broad array of technical topics related to IRAs, qualified retirement plans and other types of retirement savings and income plans, including nonqualified plans, stock options, and Social Security and Medicare.  We bring Case of the Week to you to highlight the most relevant topics affecting your business.

A recent call with a financial advisor from Minnesota is representative of a common inquiry related to distributions, spousal consent and 401(k) plans.

Highlights of Discussion

  • The short answer is, “maybe.” It depends on whether the 401(k) plan is subject to the annuity distribution requirements under the Retirement Equity Act of 1984 (REA) or is considered a “REA safe-harbor” plan.
  • REA, in part, provided spousal protections with respect to defined contribution (DC) plan distribution options, and defaulted most plan disbursements for married couples to qualified joint and survivor annuities (QJSAs) and qualified preretirement survivor annuities (QPSAs), unless the participant and spouse executed certain waivers.
  • 401(k) plans that are subject to the REA annuity mandates require plan administrators to obtain written spousal consent to distribute plan benefits in a form other than an annuity [Treasury Regulation (Treas. Reg.) 401(a)-20, Q&A 17]. REA added the requirement to have spousal consent to take a distribution so that the nonemployee spouse would have some control over the form of benefit the participant chooses and would be, at the very least, aware that retirement benefits existed.
  • Regs at 1.417(e)-1(b)(2) and 1.401(a)-20, Q&A 27 provide for the following spousal consent exceptions for REA plans:
  1. For distributions made on or after October 17, 2000, a spouse’s consent is not required if the present value of the participant’s nonforfeitable accrued benefit, including both employer and employee contributions, on the date of the distribution is ≤ $5,000;
  2. If the plan administrator is satisfied there is no spouse or the spouse cannot be located;
  3. If the participant has a court order certifying his or her abandonment; or is legally separated;
  4. If the spouse is incompetent, the legal guardian can provide consent, even if the legal guardian is the participant;
  5. The plan must make required minimum distributions even though the employee, or spouse where applicable, fail to consent to the distribution (see Treas. Reg.401(a)(9)-8, Q&A 4).
  • REA safe-harbor plans, in contrast, are DC plans that are drafted to be exempt from the REA annuity requirements. The plan document will state whether it is a REA safe-harbor plan. Many, but not all, 401(k) plans are REA safe-harbor plans. Plan administrators are not required to obtain spousal consent for a distribution if the 401(k) plan is a REA safe harbor plan.
  • The criteria to be a REA safe-harbor plan are found in Reg. 1.401(a)-20, Q&A 3:
  • At death, a participant’s vested benefit must be payable to the spouse unless the participant is not married or the spouse consents to another named beneficiary;
  • The plan participant cannot elect payments in the form of an annuity;
  • The plan administrator separately accounts for and continues to apply the REA rules to amounts transferred from other plans subject to the REA rules (e.g., money purchase pension plans or target benefit plans).

Conclusion

Some 401(k) plans are subject to REA and, therefore, require distributions to be in the form of an annuity unless the plan administrator obtains proper participant and spousal waivers. Some plans are REA safe-harbor and do not require the plan administrator to obtain spousal consent for a distribution. The terms of the plan document will specify what type of plan it is.

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