Q. The consultant for the 501(c)(3) where I have a 403(b) plan and where the employer also sponsors a 401(a) plan for employer contributions has told the employer that the Section 415(c) limit is a shared limit between the two plans. This is not my understanding! What is the answer?
A. The consultant is incorrect, since 403(b) plans are considered (for purposes of the Section 415(c) limit) owned by the participant, while the 401(a) plan is owned by the employer. This will mean there are two Section 415(c) limits of the lesser of 100% of includible compensation or the dollar limitation capped at $53,000 in 2015. A consultant would make this kind of error if the consultant is unfamiliar with the unique treatment of 403(b) plans.