FAFSA handling of Deferred Comp and/or Forgiveable Loans

Hi Everyone

Longtime lurker and grateful reader. I have searched the site and can’t find a thread on this part of the FAFSA application. I know that FAFSA is very particular about non-IRA vehicles. My question is with regard to Deferred compensation package unavailable for use until age 65 but not held in IRA vehicle. Do I include this within our assets? The other question pertains to an upfront employment package which provided upfront monies which are held in account, but are “forgivable” over a period of five years. Again, is this considered an asset although in theory the loan (monies) are only in actuality forgiveable without penalty (repayment) if the employee stays and completes the term of the employment. Hope that i’m explaining that well enough. Thank you so much!!!

That might be something to take up with the financial aid office of a particular school how they handle this.

I am not sure about the items you mentioned as far as FAFSA is concerned.

The retirement savings that is not an IRA might be an asset and the other one, a loan, might be income in the year it is forgiven? That is only a guess.

@kelsmom, do you have any ideas?

Deferred compensation plan - governmental?

Is this deferred compensation you have opted for with a private company?

Take a strong look at your income. The need based financial aid formulas are heavily weighted towards income. If your income is on the higher side, you might not qualify for need based aid regardless of your assets.

Based on the limited information provided, I would say that both the deferred compensation and the “upfront monies” held in an account would not be reported at all on FAFSA until the money vests; that is, as soon as you have complete control of the money (it’s yours to do with as you like and it does not have to be paid back), it gets reported as income for the year that it vests and it gets reported as an asset as long as it hasn’t been spent.

@BelknapPoint

How many lower paying jobs have this type of deferred compensation?

The OP needs to look at income he has now…that is the primary driver for need based aid.

To the OP…have you figured out an amount you can and will pay annually for your kid to attend college? That is an important thing to establish.

Probably not many.

http://thechoice.blogs.nytimes.com/2011/01/14/fafsaq-and-a-part-4/?_r=0

^check out question 5

I also found a thread on CC about something similar:

http://talk.collegeconfidential.com/financial-aid-scholarships/1064851-fafsa-how-to-treat-deferred-comp.html

Thank you everyone for your replies and the links. We are going to have to speak to financial aid offices directly I think. As we worked on Net Price Calculator and CSS for a financial pre-read, we made assumptions that they would not be included ~ so I am sure that the EFC is very much income driven as calculated based on the 2015 tax forms. However, if these monies were included as assets, things would re-calculate differently. And would change our EFC for sure. Trying to get our ducks in a row as early as possible. I appreciate all your suggestions and feedback.

I have never worked at a college where anyone has this sort of issue, so I’ve never had to deal with it. I agree with Mark (first link in #7) - you could ask for a PJ review. You would report the vested amount and ask the school to consider PJ to remove some of the asset.

To be honest, I doubt it would make a difference in aid at the vast majority of schools. In the case of the very top “giving” schools, it might … and I would bet those schools have dealt with this question before.

thank you so much for your feedback. I really appreciate it. I’m a fairly decent researcher and love this site but it sounds like this is something that may be a more individual scenario. Having twins, we only have one shot to do our due diligence and get it right! I dont have a lot of risk tolerance so I want to know before hand as much as we can if our EFC numbers are close to being right.

@momoftwins2017

Agreed you should check with the colleges of interest. Your kids’ actual aid determinations are made by each college. I’m sure you know by now that the vast majority of colleges do not guarantee to meet full need for all accepted students. That being the case, you may find that your actual aid awards may not fluctuate much if your twins don’t get accepted to the minority of colleges that do actually meet full need for all.

Another thought is that if your students have the GOA and ACT or SAT scores to be competitive for admissions to,the schools that do guarantee to meet full need (most are highly competitive for admissions) you might also want to see how their stats would position them for merit aid, which would not be at all dependent on your income or assets.

And lastly…please cast a wide net. Those meet full need schools that are very generous also have very low admissions…some in the single digits of applicants. They really aren’t a slam dunk for admissions for anyone.

You are smart to be looking at all of this now.

How does your W2 list the accrual? At my company, although sign on bonuses with a deferred component are rare, we would impute 20% of the deferred comp as “earned” each year- and the year end tax form would reflect that.

Monies which are held for you but which do not vest until you are 65 get a review by a tax and comp expert. Your HR representative can probably connect you to an expert at your company who can help with this.

The value of my deferred comp account is not counted as asset when I run the NPCs because it is a retirement account (like 401K, IRA, etc).
Money that funds it is deducted from my paycheck PRE-tax, so it lowers my current ‘income’, but is recorded as ‘non-taxable contributions to…’ on the NPC. So, the amount being invested now is added back in to my income, but, at least in some cases, the existing asset value is protected as retirement funds.

I haven’t had to do a CSS in several years, so off hand I don’t recall how it was handled there. (Will be reminded shortly - I have twins getting ready to apply too!)

Not sure any of that is helpful…

Thank you @blossom. Yes when my husband had that experience with sign-on bonus at his previous employer, that was how the monies showed up on his tax return as well. Each year the “forgiven” amount showed up as earnings. My husband switched firms this Spring and as a result, the accrued “forgiven” amount wont actually show up until the 2016 taxes are filed. The 2015 tax returns does not have of the additional “wages” because the event (new employer sign on bonus) didn’t actually happen until 2016. That said, we do have the asset currently (“albeit” really only a 1/5 of it, but wouldn’t appear until next year on tax forms).

I realize that next year when we go to file the FAFSA again for their sophmore year, it becomes cleaner because the money will be right there in the w2. I think the 65 vesting deferred comp he will go ahead on @WhataProcess 's suggestion and just ask his human resources officer how to show it. I really, really appreciate everyone’s help.

In terms of income…you won’t have to report 2016 income until you file the 2018-2019 FAFSA and Profile.

Where is the 1/5 of this money? For the FAFSA and Profile, if you have this in a rail ar savings or the like on the day you file the form, it will be listed as an asset for the 2017-2018 FAFSA and Profile.