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This section will take you through some special steps you should complete for the first year the plan is on the ftwilliam.com Compliance system. In general, once these set up steps are completed, you should not have to repeat them for future years unless plan specifications change or you choose to capture different census data for a plan.
If it is not the first plan year a plan is in existence, the system will not have a history of service, compensation and other information that may be necessary for testing. There are therefore a few extra steps to take when setting up an existing plan for testing on the ftwilliam.com Compliance system. These steps will also be explained below.
New plan
If it is actually the first year for a given plan, you must select this in the Plan Specifications menu under "General Features/Accounts and Sources" you will find the question "Indicate if this is the first Plan Year for a new plan" in the first section (General Plan Features). For the first plan year, most of the information necessary to do calculations and make determinations will be provided in the census and plan specifications. There may be a few extra pieces of information that you will want to include through the Other Import/Export/Reports Menu, depending on how extensive your census spreadsheet is (ownership information, etc.).
If you enter information into the Other Import/Export/Reports Menu necessary for the census data scrub, you must first upload census data information, second upload/enter "Other Import/Export/Reports" data and finally, run the data scrub. This is because uploading a new census will clear out any current year testing data (fields marked with an "R") that may be entered on the "Other Import/Export/Reports" menu.
Existing plan
If it is not the first plan year for a plan but only the first year the plan is on the ftwilliam.com Compliance system, then there are at least a few extra data fields and/or spreadsheets that we suggest uploading to the system for proper testing (e.g. beginning balances and a variety of census data like earliest date of hire, cumulative years of service for vesting purposes, prior year compensation, etc.). Some different options are discussed below:
- Census Data Supplemental. The system has a default grid "Census Data Supplemental" that is set-up with a number of fields that are useful for a plan with multiple years of history. You can view/change the fields that are in the Census Data Supplemental grid under the Work With Data Entry Grids menu.
To upload or enter data into the Census Data Supplemental grid, you should first upload your census data for the plan. After that information is uploaded, you can go to the Other Import/Export/Reports Menu. You will need to select the Census Data Supplemental grid from the drop down box in one of the grids provided (you may want to select this for a User Defined Grid "UD Grid") and click on "Select Grids" towards the bottom of the page. Once the grid is selected you will have options to Edit data (where you can manually enter the information directly in the system), download a blank spreadsheet, upload a spreadsheet and print the grid. Once the census data and supplemental data have been entered into the system, you can do a Census Data Scrub to process the information.
The order you enter information is important because uploading a new census will clear out any current year testing data (fields marked with an "R") that may be entered on the "Other Import/Export/Reports" menu. Review the errors and census data reports carefully to ensure you have provided sufficient information to properly test the plan.
- First year census. As an alternative to the supplemental census, you could set-up a "first-year" census to use for plans new to the ftwilliam.com Compliance system that combines the normal census information, plus supplemental census data under the Work With Data Entry Grids menu. Under this scenario, little to no data would need to be uploaded via the Other Import/Export/Report Menu before a census data scrub is run.
- Prior year end. If possible, we also suggest adding plan year end data for at least the prior plan year to assist in providing a more full history for the system to use (including ownership and family relationship information; ending balances in the transaction menu; for example).
Depending on the amount of information you enter in the prior year-end, you will have more testing power in the current testing year. For example, if you would like to test top-heavy status for the current testing year (2009, for example) then it is necessary to know the balance of participants” accounts in the plan (ending balances under the transactions menu) as of the determination date for the testing year (12/31/08 for a calendar year plan).
For the first year on the system, you will need to enter an earliest date of hire at a minimum to account for service history. Some service history defaults that may apply in the first testing year depending on the extent of prior year data loaded on the system (each of these defaults will appear as an error after a census data scrub if applicable):
- If service is not known, the system will assume full-time work but will actually show "9999" as hours earned in the Eligibility history link. You can view the eligibility history link in the Service history grid under the Other Import/Export/Report Menu (more specifically, here).
For example, if it is the 2009 plan year end and you have a 2001 hire date without any hours of service provided before 2009, the system will decide that this person has 8 years of eligibility service history. In the Eligibility history link, the 2001 hire date will appear; and eligibility for each contribution type will appear with 9 years of service earned and hours of "9999".
- If a person has a hire date before the first day of the plan year, the person is eligible for the contribution and the entry date is not known, the system will use the day before the plan year as the entry date.
- Date met will default to the first day of prior plan year if a participant is found eligible and specific entry date is not known (not in the plan year end being tested, prior plan year ends on the system and not in the supplementary/first testing year census). Exception: if no service required, date met will be the same as the earliest date of hire.