Non-Qualified Savings Plan FAQs

Here are answers to frequently asked questions about the Non-Qualified Savings Plan (NQSP), participation, features, account access and more.
What is an NQSP?

An NQSP is a type of tax-deferred, employer-sponsored retirement plan offered by companies to provide eligible highly compensated employees with additional retirement savings opportunities and tax benefits. Non-qualified plans supplement retirement savings that cannot be contributed to a qualified retirement plan due to IRS limits on pay.

What are the IRS limits on pay?
  • IRS pay limit: The IRS caps the amount of annual pay that is considered eligible for the 401(k) Savings Plan. For 2023 the pay limit is $330,000 and for 2024 the pay limit is currently projected to increase to $340,000.
  • IRS contribution limits: The IRS caps the annual amount you can personally contribute to an employer- sponsored retirement plan, like BMO’s 401(k) Savings Plan. For 2023, the contribution limit is $22,500; or $30,000 starting in the year you turn 50 if you elect to make additional 401(k) catch-up contributions. For 2024, the contribution limit is currently projected to increase to $23,000; or $30,500 starting in the year you turn 50 if you elect to make additional 401(k) catch-up contributions.
  • These limits are subject to change annually as determined by the IRS (typically announced in late October for the following calendar year).
Am I eligible to participate in the NQSP?

You can participate in the NQSP in two ways:

  1. BMO’s Core Contribution: If your eligible pay exceeds the IRS pay limit, you will automatically receive a 2% Core Contribution from BMO on eligible pay between the IRS pay limit and $500,000.
  2. Your contributions and BMO’s Match: If eligible, you may have the opportunity to contribute your own pay to the NQSP on a before-tax basis, and receive a BMO Match on your contributions. You will receive an invitation to participate annually if BMO determines you are eligible for the plan.
How do I participate in the NQSP?

To participate in the NQSP for 2024, you must take action during the election period open Wednesday, October 11 through Friday, October 27, 2023. If you do not make an election during this period, you will not be able to contribute to the NQSP in 2024. The next election opportunity will be in the fall of 2024, for the 2025 calendar year.

Do I need to enroll or re-enroll in the NQSP?

Yes. You must enroll or re-enroll each year. Making contributions from your pay to the NQSP is voluntary. If you want to contribute for 2024, you must make an election during the election period. If you don’t have an election in place by the October 27, 2023 deadline, you’ll have to wait until the next annual election period in the fall of 2024 to begin making personal contributions to the plan. Once the election period ends your choice to participate, or not participate, for the following year is irrevocable.

Remember, if you have excess pay in a given calendar year, you’ll receive the 2% Core Contribution from BMO, even if you don’t make an election to contribute pay into the NQSP for that year.

Note: Even if you don’t make an election to personally contribute pay into the NQSP, you can still make a distribution and investment election for your 2% Core Contribution during the election period.

I think my pay might exceed the IRS pay limit. Why didn’t I receive an invitation to participate in the plan?

BMO used a detailed analysis of past and expected future pay in our selection process. It is possible that, due to a number of factors, such as a recent job change that recently increased your pay, you were not selected to participate for the upcoming year. If your pay does exceed the IRS pay limit, you will receive BMO’s 2% Core Contribution on your excess pay, and will likely be invited to participate in the plan with the opportunity to make personal contributions in a future year.

If you feel an error was made, you can contact an Empower Non-Qualified Savings Plan Client Service Team member at 1-800-824-0040. Explain why you believe you should participate no later than the end of the current election period. Once the election period ends, no exceptions can be made, and you will need to wait until the next annual election period.

What types of pay are considered for the NQSP?

Your eligible pay generally includes your base pay, overtime, shift differential and any variable pay that is related to work performance. Variable pay includes:

  • Team-based plans (based on company, corporate, department or unit performance, including production and productivity plans)
  • Sales, incentive, and commission-based plans
  • Business referral plans
  • Ad hoc cash awards related to performance

However, due to certain IRS provisions that govern NQSPs, payroll deductions for your personal contributions will only be taken from your base pay (such as salary, vacation, sick pay) and your annual performance award, such as Short-Term Incentive Pay (STIP). This excludes sales incentives and commission pay. While sales incentives and commission pay is excluded for purposes of your personal contributions, it will still be used in determining your overall eligibility for the NQSP.

What is excess pay?

As it relates to the NQSP, excess pay generally refers to your eligible pay that is between the IRS pay limit and $500,000. For 2023 the pay limit is $330,000 and for 2024 the pay limit is currently projected to increase to $340,000 but is subject to change each year as determined by the IRS.

How is my excess pay used to calculate benefits under the NQSP?

There are certain differences in how your excess pay is used to calculate contributions both you and BMO make to the NQSP, as follows:

  • BMO’s Core Contribution: You will receive a 2% Core Contribution on the total amount of your excess pay.
  • Your contributions: You may be eligible to make personal, before-tax contributions to the plan from 1% to 75% of your eligible excess pay. The money you contribute is deducted from your pay each pay period.
    IMPORTANT. Due to certain IRS provisions that govern non-qualified savings plans, payroll deductions for your personal contributions will only be taken from your base pay (such as salary, vacation, sick pay) and your annual performance award, such as Short-Term Incentive Pay (STIP), but exclude sales incentives, commission pay and certain bonuses. You cannot make personal contributions from any pay you earn under a sales, incentive, or commission-based plan, but these types of pay will still be used in determining your overall eligibility for the plan, and the amount of BMO’s Matching and 2% Core Contributions.
  • BMO’s Match: You will receive a dollar-for-dollar match on your contributions, limited to 5% of your total excess pay.
Am I vested in my NQSP?

You’re vested in BMO’s 2% Core Contributions after three years of BMO service (including prior service). Your personal contributions and BMO’s Matching Contributions are vested immediately.

Why am I being asked to make my fiscal year 2024 STIP Award deferral election during the October 2023 election period, rather than April 2024?

IRS regulations require NQSP participants to make contribution elections prior to the start of the performance period for which that pay is earned. Because of the timing of BMO’s fiscal year, this means we are now required to collect your STIP Award deferral election at the same time as your election to participate in the NQSP.

IMPORTANT. When you submit your NQSP election online, you will also choose when you want to receive payment of your FY2024 STIP award, either in December 2024 or January 2025, if eligible.

How do contributions to the NQSP change my taxes?

Payment of Federal income tax and most state/local income tax is not applicable until you receive your account distribution on NQSP contributions made by you or BMO. You will pay current FICA taxes (Social Security and Medicare), as applicable, on amounts you contribute to the plan at the time they are deducted from your pay.

In addition, the value of BMO’s Matching and vested Core Contributions will be included in your pay for FICA tax purposes at the time they are contributed to the plan. If you are not yet vested in the 2% Core Contribution, the value will not be included in your pay until you become vested. By paying FICA taxes on the contributions at the time they are contributed to the plan, you will benefit from not needing to pay FICA taxes on these contributions, or the investment earnings on these contributions when you receive your distribution from the plan in the future.

At the time you begin to receive your distribution from the NQSP you may be asked to complete a tax Form W-9 (if you are a U.S. citizen or resident alien residing outside the U.S.) or W-8BEN (if you are a non-U.S. citizen and the beneficial owner of an amount subject to U.S. withholding) before we will issue your payment.

I previously enrolled in the NQSP. Why have I not had any contributions deducted from my pay?

If your annual Short-Term Incentive Pay (STIP) makes up most, or all, of your compensation that exceeds the limit on eligible pay, then you likely will not see your first NQSP contributions until your STIP is paid, either in December or January.

What investment options are offered in the NQSP?

You can invest your NQSP contributions in a variety of investment funds offered within the plan. You have the ability to change your investment election at any time. If you do not choose an investment fund, contributions will be automatically invested in the BlackRock LifePath target date retirement fund nearest to the date you turn age 65.

The investment line-up is:

Fund Ticker
Goldman Sachs Financial Square Government Fund (Institutional Class) FGTXX
Target Date Retirement Funds Ticker Default Investment
(based on your birth year)
BlackRock Index Retirement Fund
(Class K)
LIRKX 1957 or earlier
BlackRock Index Retirement 2025 Fund
(Class K)
LIBKX 1958 to 1962
BlackRock Index Retirement 2030 Fund
(Class K)
LINKX 1963 to 1967
BlackRock Index Retirement 2035 Fund
(Class K)
LIJKX 1968 to 1972
BlackRock Index Retirement 2040 Fund
(Class K)
LIKKX 1973 to 1977
BlackRock Index Retirement 2045 Fund
(Class K)
LIHKX 1978 to 1982
BlackRock Index Retirement 2050 Fund
(Class K)
LIPKX 1983 to 1987
BlackRock Index Retirement 2055 Fund
(Class K)
LIVKX 1988 to 1992
BlackRock Index Retirement 2060 Fund
(Class K)
LIZKX 1993 or 1997
BlackRock Index Retirement 2065 Fund
(Class K)
LIWKX 1998 or later
Target Risk Funds Ticker
Conservative: BlackRock 20/80 Target Allocation Fund
(Class K)
BKCPX
Moderate: BlackRock 40/60 Target Allocation Fund
(Class K)
BKMPX
Balanced: BlackRock 60/40 Target Allocation Fund
(Class K)
BKGPX
Growth: BlackRock 80/20 Target Allocation Fund
(Class K)
BKAPX
What are my account distribution options?

Unlike other retirement plans, when you participate in a NQSP, you must also choose in advance how your account balance will be paid to you during the election period. You can choose:

  • Lump Sum: You will receive your full account balance in one payment made approximately 60 days following your retirement or date you otherwise leave BMO for any reason.
  • Installments: You will receive your full account balance in annual payments made over five or ten years. Payments will be made at the beginning of the calendar year following the year you retire or otherwise leave BMO for any reason, and every January thereafter.

The choice applies to both your contributions and BMO’s contributions made to your account during the next plan year, and any investment earnings. During each subsequent election period, you have the ability to make a new distribution choice for the following year only.

If you do not make a distribution election, or if your vested account balance is less than $50,000 when you retire or otherwise leave BMO for any reason, you will receive your account balance in a lump sum. Your distribution is not eligible for a roll-over to an IRA or other qualified retirement plan (like a 401(k) plan).

How do I access my NQSP account online?
You access your NQSP account the same way you access your 401(k) Savings Plan account. The most convenient way to connect to your account is online through Workday.
  • Empower from Workday – (no password required)
    1. Go to Workday, click Pay application
    2. Under External Links, click 401(k) to connect to your Empower account
  • For those employees who have relocated from the U.S. to another country: Empower Online from Workday – (no password required)
    1. Go to Workday, click More Tools application, then click HR Intranet
    2. Under Benefits, click Retirement, then click U.S. Retirement Savings Program (make sure you are viewing the BMO U.S. tab)
    3. Click on Login to 401(k) from the menu on the right-hand side to connect to your Empower account
  • Empower Online – from any internet enabled device (User Name/Password required) Access your account online with your Empower username and password to access your account. Go to Empower.

  • Empower App – from any mobile device Download the Empower app from the App Store or Google Play. Note: To register, click the Register button, select I do not have a PIN and follow the prompts to create a username and password.

How will I get my account information?

You will have access to your NQSP account statements through Empower. The site allows you to view real-time data about your account or print PDF statements.

Who can I contact if I have more questions?

If you have more questions about the NQSP or the upcoming election period, you may contact an Empower NQSP Client Service Team member at 1-800-824-0040.

  • You will be prompted to enter your SSN and PIN (use the same PIN you use to access the 401(k) Savings Plan).
  • Follow the menu prompts to be directly connected with an Client Service Team member, Monday to Friday, 7 a.m. to 9 p.m. Central time, or Saturday, 8 a.m. to 4:30 p.m. Central time.
    Note: If you wish to speak with an NQSP Client Service Team member, you will need your PIN. If you have forgotten your PIN, follow the prompts to receive a phone call or text message to the phone number on file with your PIN. You can also press “0” to be transferred to a customer service representative. Ask to speak directly to the NQSP Client Service Team to assist with the BMO NQSP.
Example: How to maximize your benefit under the Non-Qualified Savings Plan if your pay includes sales, incentive, or commission-based pay

In this example, David earns a $120,000 base salary and has earned commission pay of $290,000. David understands his BMO 2% Core Contribution and dollar-for-dollar Matching Contribution up to 5% are based on his total excess pay (base plus commission pay). Therefore, in order to maximize his savings potential under the NQSP, David elects a higher contribution percent of 20%, which only applies to base-pay, but not his commission pay.

Please rotate your device to see the table.

Eligible Pay Excess Pay NQSP Contributions
Base Commission Base Commission BMO 2%
Core

David’s
20%
Contribution

BMO 5%
Match

January

$10,000 $60,000

February

$10,000 $5,000

March

$10,000 $5,000

April

$10,000 $60,000
May $10,000 $5,000

June

$10,000 $5,000
July $10,000 $65,000
August $10,000 $5,000
September $10,000 $5,000
October $10,000 $15,000 $50,000 $1,000
November $10,000 $5,000 $300 $2,000 $2,000
December $10,000 $5,000 $300 $2,000 $2,000

TOTAL

$330,000

$80,000 $1,600 $4,000 $4,000

In comparison, David’s co-worker Stacey earns exactly the same amount during the year, but she has a $120,000 base salary and received a $290,000 STIP in December with no sales, incentive, or commission-based pay.

Stacey personally contributes 5% of her pay to the plan in order to maximize her BMO Match. Although David and Stacey elected different contribution percentages, they end the year with the same benefit amount. This is because David understood what his commission-based pay meant for him and intentionally elected a higher contribution amount in an effort to maximize his savings potential.

Please rotate your device to see the table.

Eligible Pay Excess Pay NQSP Contributions
Base STIP Base STIP BMO 2%
Core

Stacey’s
5%
Contribution

BMO 5%
Match
January $10,000
February $10,000
March $10,000
April $10,000
May $10,000
June $10,000
July $10,000
August $10,000
September $10,000
October $10,000
November $10,000
December $10,000 $210,000 $80,000 $1,600 $4,000 $4,000

TOTAL

$330,000

$80,000 $1,600 $4,000 $4,000

Note: This example assumes a $330,000 IRS pay limit. The limit is subject to change annually as determined by the IRS.