Census Workshop for the 2006 Plan Year January 2007
AUL’s Retirement Services Awards & Recognition Based on a plan sponsor survey from 65 plans AUL rated in the top 10 for: Customer Service Education/communication Plan administration Recordkeeping In the November 2005 issue of PlanSponsor magazine, AUL earned six “Best in Class” awards: Plan sponsor internet services Participant communication materials Participant call center Timelines of reporting Clarity of participant statements Loan/withdrawal turnaround As of January 2006:
AUL’s Retirement Services Communication Awards & Recognition Best of Show (first place) Custom enrollment communications program in the Group Pensions Category Silver (second place) Top 100 Publicity Material for 2005 “Premier Proposal” packaging Honors “Welcome to Retirement Services” product overview brochure Ranked AUL number Two in highest overall satisfaction among 30 retirement plan providers. The key drivers of the overall satisfaction were: Wholesaler market knowledge/expertise Wholesaler responding quickly to calls Wholesaler product knowledge/expertise Wholesaler accessibility and availability
Census Workshop Agenda Overview Highly Compensated and Key Employee Definitions Compensation Discussion ExACCT Software Demonstration Pension Protection Act of 2006 (PPA) Please complete the feedback survey and fax to the number on the survey!
Why Collect Census Data? Forfeiture reallocation Profit sharing contribution calculation IRS compliance testing Annual report DOL/IRS Form 5500 Participant status and vesting updates
Compliance Testing
What Tests May Apply? Required Annual TestMandated by Coverage Testing IRC Section 410(b) Annual Additions Limit TestIRC Section 415 ADP Testing IRC Section 401(k) ACP Testing IRC Section 401(m) Top Heavy Testing IRC Section 416 Annual Deferral LimitIRC Section 402(g)
What Tests May Apply? Required Annual TestMandated by Depending on Plan design, you may also need: Benefits Right & FeaturesIRC Section 401(a)(4) General TestIRC Section 401(a)(4) Average Benefits TestIRC Section 410(b) (Additional fees will apply) AUL Does Not Perform the Following: Compensation DefinitionIRC Section 414(s)
Compliance Testing Testing overview handout –See handout for brief description of tests –For more information: Census Instructions on
Timing of Tests Tests performed after final contribution date stated on census Prior to testing: –Profit Sharing contributions must be received –Matching amounts must be included in census, but do not need to be received –For multiple plans, all contributions (except match) and census must be received
Who’s a Highly Compensated Employee (HCE)? A more than 5% owner in the current or prior plan year –Includes family members Tip: Grandparent, parent, spouse, child Earned greater than $95,000 in prior (2005) plan year –Compensation = total compensation –If elected in your Adoption Agreement or your plan document, the top paid group may apply. Note: If your plan has an anniversary date beginning other than January 1, and you have elected to use calendar year data to determine HCEs (see your Adoption Agreement or your plan document or plan document), then substitute $100,000 for the $95,000 amount shown above. See the “Census Instructions” on eSponsor at
Summary of Family Attribution Family Attribution as it applies to 5% ownership: –SpouseSpouse –Parent Child –Grandchild Grandparent No attribution from grandparent to grandchild No attribution between siblings No attribution between in-laws Yes attribution between step-children and parents Between To Between
Who’s a Key Employee? Officer with compensation greater than $140,000 A more than 5% owner –Includes family members A more than 1% owner with compensation greater than $150,000 –Includes family members with compensation greater than $150,000 Note: Not all Key Employees are Highly Compensated & vice versa. See Census instructions for more detail.
Census Data Collection
Reporting Employees and Hours Reporting all employees is necessary for: –Testing services –Annual reports –5500 reporting
Reporting Employees and Hours Hours are required for: –Testing services –Vesting calculations –Participant eligibility To receive forfeiture reallocations and/or employer contributions –Employees working greater than 1,000 hours report 1,000
Status Codes Employment Status Plan Status Testing Status Review “Census Instructions” for details on eSponsor at
Plan and 415 Compensation There may be multiple definitions of compensation for different tests Refer to the Compensation Guide in the handouts If Plan and 415 Compensation are the same, provide the data in both places on your census Note:For 2005, the compensation limit is $210,000. For 2006, the limit is $220,000
Partial Year Compensation Partial year compensation (comp.): –Applies to employees who are eligible after the first day of the plan year –Eligible does not mean actively contributing or receiving contributions Partial year comp. “A”: –Earned from entry date to end of the plan year Partial year comp. “B”: –Earned from entry date to end of plan year for match and/or employer if requirement different than deferral requirement
Partial Year Compensation Example Joe Employee –Hired 1/1 –Eligible for deferrals 4/1 –Eligible for match 7/1 415 Compensation: –1/1 to 12/31 Plan compensation full year: –1/1 to 12/31 –Your Adoption Agreement or your plan document defines this period Partial year compensation “A”: –4/1 to 12/31 Partial year compensation “B”: –7/1 to 12/31
Catch-Up Contributions Must be 50 by the end of the calendar year and exceed one of the following: –402(g) deferral limit ($15,000 in 2006) –415 annual additions limit ($44,000 in 2006 or 100% of pay) –Plan deferral limit (see Adoption Agreement or your plan document) –ADP limit (not known until ADP testing) Employees can defer additional money: –$5,000 in 2006 –$5,000 in 2007
Catch-Up Contributions Contributions will automatically be reclassified as catch-up if failure of: –ADP Test –402(g) Limit –415 Test –If catch-up limit not met Dedicated field to report catch-up contributions –Do not include in deferral amount
Example: –Joe is age 50, earns $50,000, defers 30% Joe intends to defer the maximum amount, $15,000 –Effective July 1 Joe’s salary was increased by 5% Joe does not reduce his deferral percentage $1,250 additional salary through end of year X 30% deferral rate increases deferral by $375 –$375 is re-characterized as catch-up contribution –Many payroll systems support separate calculation of employee deferrals –Another example is bonuses – are they subject to deferral calculation? Catch-Up Contributions
Roth 401(k)/403(b) Roth Deferrals –Roth monies must be separately accounted for –Separate accounting must continue until Roth completely distributed –No forfeitures should be allocated to Roth –Roth deferral election is required –Roth catch-up allowed but subject to limit
Roth 401(k)/403(b) Deferrals – cont’d –Part of ADP test –Subject to 402(g) limit –Part of top-heavy calculation –Subject to 415 limit –Corrective distributions are NOT qualified distributions
For Help Determining What Data to Report … Please refer to Census Instructions Instructions located at: –OneAmerica website: –Call your Plan Services Consultant
For Help With Hardware or Software Questions … Please refer to the ExACCT User Guide Most recent guide located on OneAmerica website: – Plan Services Consultant Data Transmission Unit (800) ext 7472
Dates to Remember January, 2007 (See handout) –Deadline to send in your census and final contributions –This will guarantee testing completion by March 15, 2007 – sent December, 2006 March 15, 2007 –First IRS test refund deadline if your plan fails –Refunds processed by this date will not incur 10% corporate excise tax
Dates to Remember April 2, 2007 –Second deadline for your census if you missed the January deadline –AUL will begin processing other year-end services (annual report, 5500, etc.) –Late census will incur re-work fee of $300 per item if already complete
ExACCT Software Presentation Time for a 15 minute break Next Up …
O NE A MERICA ® companies: A MERICAN U NITED L IFE I NSURANCE C OMPANY ® O NE A MERICA S ECURITIES, I NC. P IONEER M UTUAL L IFE I NSURANCE C OMPANY A stock subsidiary of American United Mutual Insurance Holding Company R.E. M OULTON, I NC. T HE S TATE L IFE I NSURANCE C OMPANY