PLANADVISER - November/December 2020 - 10

trends
The news that drives the retirement
plan adviser industry
Tracking Part-Timers' Hours
How they count
hours, implement
cash-outs and
find missing
participants are
some of the
processes plan
sponsors need
to review for the
SECURE Act's new
requirement
THE Setting Every Community Up for
Retirement Enhancement
(SECURE) Act
demands that employers maintaining a
401(k) plan have a dual-eligibility requirement,
starting this coming January 1,
to enable part-time workers to join the
retirement plan. Under this requirement,
an employee must complete either one
year of service, with at least 1,000 hours
worked, or three consecutive years, with
at least 500 hours worked in each.
2021 is when employers must start
counting hours for eligibility purposes.
Plan sponsors may choose to allow parttimers
to share in any type of employer
contribution, but they are only required
to let those employees make deferrals.
The SECURE Act also says plan sponsors
" may elect to exclude " these employees
from nondiscrimination and coverage
testing, as well as from the application of
top-heavy rules.
Most part-time employees are paid by
the hour, so the employer should have
records of the hours worked, says Patricia
Martin, an attorney with Husch Blackwell.
For employees who are paid on a
daily or a piecework basis, the employer
may have to use the " equivalencies "
under Department of Labor (DOL) regulations.
" For example, if an employer does
not keep track of actual hours worked, it
would give 10 hours of service for each
day on which the employee worked, "
Martin explains.
She adds that some employers may
choose to just make everyone eligible
to make elective deferrals, regardless of
hours worked.
However, counting hours for vesting gets
10 | planadviser.com November-December 2020 Art by Nadja Zinnecker

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PLANADVISER - November/December 2020

Table of Contents for the Digital Edition of PLANADVISER - November/December 2020

Value Judgement
2020 PLANADVISER Practice Benchmarking Survey
Retirement-Plus
Client Onboarding
Expanding Plan Access
Sequence of Return Risk
The DOL's Latest Proposed PTE
Are You a QPAM?
PLANADVISER - November/December 2020 - Cover1
PLANADVISER - November/December 2020 - Cover2
PLANADVISER - November/December 2020 - 1
PLANADVISER - November/December 2020 - 2
PLANADVISER - November/December 2020 - 3
PLANADVISER - November/December 2020 - 4
PLANADVISER - November/December 2020 - 5
PLANADVISER - November/December 2020 - 6
PLANADVISER - November/December 2020 - 7
PLANADVISER - November/December 2020 - 8
PLANADVISER - November/December 2020 - 9
PLANADVISER - November/December 2020 - 10
PLANADVISER - November/December 2020 - 11
PLANADVISER - November/December 2020 - 12
PLANADVISER - November/December 2020 - 13
PLANADVISER - November/December 2020 - Value Judgement
PLANADVISER - November/December 2020 - 15
PLANADVISER - November/December 2020 - 16
PLANADVISER - November/December 2020 - 17
PLANADVISER - November/December 2020 - 2020 PLANADVISER Practice Benchmarking Survey
PLANADVISER - November/December 2020 - 19
PLANADVISER - November/December 2020 - 20
PLANADVISER - November/December 2020 - 21
PLANADVISER - November/December 2020 - 22
PLANADVISER - November/December 2020 - 23
PLANADVISER - November/December 2020 - 24
PLANADVISER - November/December 2020 - 25
PLANADVISER - November/December 2020 - Retirement-Plus
PLANADVISER - November/December 2020 - 27
PLANADVISER - November/December 2020 - 28
PLANADVISER - November/December 2020 - 29
PLANADVISER - November/December 2020 - Client Onboarding
PLANADVISER - November/December 2020 - 31
PLANADVISER - November/December 2020 - Expanding Plan Access
PLANADVISER - November/December 2020 - 33
PLANADVISER - November/December 2020 - Sequence of Return Risk
PLANADVISER - November/December 2020 - 35
PLANADVISER - November/December 2020 - 36
PLANADVISER - November/December 2020 - 37
PLANADVISER - November/December 2020 - The DOL's Latest Proposed PTE
PLANADVISER - November/December 2020 - Are You a QPAM?
PLANADVISER - November/December 2020 - 40
PLANADVISER - November/December 2020 - Cover3
PLANADVISER - November/December 2020 - Cover4
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