CERTIFIED FINANCIAL PLANNER CERTIFICATION PROFESSIONAL EDUCATION PROGRAM Retirement Planning & Employee Benefits Session 3 Fundamentals of Qualified Plans ©2015, College for Financial Planning, all rights reserved. Session Details Module(s) 2, 4 Chapter(s) 3, 2 LOs 2-3 4-2 Calculate and analyze whether a defined benefit plan meets participation and eligibility requirements. Identify the minimum coverage rules for 401(k) plans, including the ADP and ACP tests. 3-2 What Makes a Plan Qualified? • ERISA • Minimum participation and coverage • • • • requirements Non-discriminatory Minimum vesting requirements Minimum funding requirements (pension plans) Protection of assets 3-3 Qualified & Nonqualified Plans Qualified Plans Nonqualified Plans Pension Plans Profit Sharing Plans (DC) Tax-Advantaged Plans Other Nonqualified Plans Defined Benefit (DB) Profit Sharing Traditional IRA Section 457 Plans Cash Balance (DB) Thrift Plan Roth IRA Stock Bonus SIMPLE IRA ISO Money Purchase (DC) ESOP (LESOP) SEP ESPP Target Benefit (DC) Age-Weighted (SARSEP) NQSO 403(b) (TSA) Deferred Compensation Plans Cross-Tested (Comparability) 401(k) Plan SIMPLE 401(k) 3-4 Why install a qualified plan? • Recruit, Retain, Reward • Employer deducts contributions • • • • o Up to 25% for defined contribution o As much as needed to fund $210k benefit (2015) in defined benefit Tax-deferred growth for employee in DC Guaranteed benefit for employee in DB Free money! Protection of assets 3-5 Plan Features • • • • • • Eligibility Service definition Plan formula Participant contributions Compensation definition Normal retirement age • • • • • • Early retirement Investment Vesting Plan limitation year Death benefits Actuarial assumptions 3-6 Qualified Plan Vesting Schedules Completed Service Years Defined benefit pension plans (non-top heavy) Top-heavy defined benefit pension plans and defined contribution plans 1-2 3 4 5 6 7 1 2 3 4 5 6 Cliff Vesting % Vested Graded Vesting % Vested 5-Year Cliff 3-to-7-Year Graded 0% 0% 0% 100% 100% 100% 0% 20% 40% 60% 80% 100% 3-Year Cliff 2-to-6-Year Graded 0% 0% 100% 100% 100% 100% 0% 20% 40% 60% 80% 100% 3-7 Top-Heavy Plans A defined contribution plan Is top heavy if A defined benefit plan The aggregate account balances* For key employees exceed(s) 60% of The present value of cumulative accrued benefits For all employees The present value of cumulative accrued benefits The aggregate account balances* * Includes benefits derived from contributions except “deductible employee contributions”; also includes amounts distributed in current plan year due to separation and any in-service distributions in the preceding four plan years. 3-8 Key Employee Any employee who, at any time during the plan year containing the determination date for the plan year to be tested, met any of the following criteria: 1. was a “5% owner” (ownership of > 5%) 2. owned 1% of the company and received compensation > $150,000 3. was an officer of the company and received compensation >$170,000 in 2015 3-9 Identify Key Employees XYZ Corporation Name Officer Compensation Ownership % Kerry Yes $190,000 50% Gregg Yes $180,000 None Ron Yes $120,000 25% Gina Yes $110,000 20% Mark No $80,000 1% Kevin Yes $70,000 1% Jeff Yes $60,000 1% Steve No $58,000 1% Cathy Yes $48,000 1% 3-10 Identify Key Employees XYZ Corporation Key employees include: Kerry, Gregg, Ron, and Gina 1. 5% Owners: Kerry, Ron, and Gina 2. 1% owner and compensation > $150,000: none 3. Officer with compensation >$170,000 (2015): Gregg The number of officers who can be considered key employees based on their title and compensation is the greater of 10% of all employees, or 3 (but in no case more than 50). 3-11 Top-Heavy Plan Requirements Accelerated Vesting • 3-year cliff or 6-year graded Minimum Contributions and Benefits to be paid to Non-Key Employees • Defined Contribution Plan • o Plan must provide a contribution of at least 3% of compensation per year, or, if less, the percentage contributed for key employees. Defined Benefit Plan o Plan must provide a minimum benefit of 2% of employee’s highest 5-year average compensation for each year of service earned while plan is top-heavy, to a maximum of 20%. 3-12 Minimum Funding Requirements • • • • Actual plan results are compared to estimated amount needed to provide promised plan benefit. Minimum funding requirement: employer must contribute at least a minimum amount to fund the plan benefit. If account value exceeds minimum required to fund benefit, contribution is decreased. If plan is underfunded there is a 10% penalty tax. 3-13 Defined Benefit Plan Termination (1) Overfunded plans must either • transfer 25% of the potential reversion to a qualified replacement plan, or • increase the participants’ accrued benefits by at least 20%. 3-14 Defined Benefit Plan Termination (2) Underfunded plans (involves PBGC) • voluntary standard termination • voluntary distress termination • involuntary termination • maximum monthly amount guaranteed by PBGC at age 65 is $5,011 paid out over participant’s lifetime; lump sum option is not available 3-15 DB Plans Exempt From PBGC • Plans maintained for substantial business • owners only (such as sole business owners or greater than 10% business owners) Plans maintained by professional service employers that have never had more than 25 active participants 3-16 PPA Disclosure Requirements • New under PPA • Disclosures include o summary of plan participants, o information about funding status of plan, and o allocation of assets • PBGC overview and what it guarantees must also be provided 3-17 Question 1 Which of the following could be expected to reduce the annual cost of a defined benefit plan? I. a high turnover assumption II. use of salary scales III.a high interest rate assumption IV. a high benefit cost assumption V. a low turnover assumption a. I and II only b. I and III only c. II and IV only d. I, II, and III only e. II, IV, and V only 3-18 Question 2 Which of the following are characteristics of a voluntary standard termination? I. The plan must have sufficient assets to meet benefit liabilities. II. The plan has insufficient assets to meet benefit liabilities. III. Plan assets must be distributed in accordance with ERISA requirements. IV. This type of termination would be used if the employer wanted to terminate a defined benefit plan and offer a defined contribution plan instead. V. The employer is assessed a 50% penalty tax on asset reversions. a. I and IV only b. II and III only c. I, III, and IV only d. II, III, and V only e. I, III, IV, and V only 3-19 CERTIFIED FINANCIAL PLANNER CERTIFICATION PROFESSIONAL EDUCATION PROGRAM Retirement Planning & Employee Benefits Session 3 End of Slides ©2015, College for Financial Planning, all rights reserved.