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About HarleyBabe

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  1. I too am a small TPA firm wishing to expand my business in the DC area. Would you be willing to discuss?
  2. Question if a plan chooses to amend their safe harbor to have a 1 year wait, but leave the deferral portion with immediate entry, do we need to test those individuals in the ADP/ACP because they didn't receive a safe harbor for not meeting the service requirement yet? What other pitfalls are there for putting a one year wait on the safe harbor other than the top heavy concern which would negate the 1 year wait we are aware of.
  3. I don't have the 403(b) Answer Book unfortunately.
  4. Sorry if this is an overlap. I did search and there was just too many posts to go through so questions is: Have a Non-Erisa 403(b) Plan wishing to terminate. Funding vehicle says Custodial Accounts. What am I as TPA required to provide the plan sponsor other than the termination resolution for this process. Do I need to prepare a Notice for participants and if so, what information should it provide, and what should I convey to the client regarding this termination process? I was reading about a 12 month rule for distributions to be all out. I am just not versed on 403(b) termination and want to make sure I provide all the information correctly for the client and the participants. Thank you.
  5. To further this question, I had to amend the 403(b) to allow for Inservice Distribs. When I did this, I had the Trustees sign. I'm being told the 403(b) doesn't have Trustees and that is incorrect. Thoughts? It is not an ERISA plan? Also, the plan sponsor who signed the 2009 document is not longer there. When I changed it with current folks I called them Trustees, would the opinion be I need to change this?
  6. My feeling as well. I have been waiting for the 2 year window. I was not under the impression that 403(b) plans had to be amended with PPA and were separate.
  7. Did 403(b) plans have to be amended for PPA? This is a Non-Erisa B Plan. Our last amendment was 2009. Thanks
  8. Yep I saw this in WRERA, unfortunately they still don't get it. I just wanted to make sure I wasn't missing something. I have ERISA counsel addressing this with them now as to why withholding applies.
  9. Yes I am the TPA and it is a DC plan and I totally disagree with him but he believes one of his employees who thinks she is a pension professional. I am just tired of arguing with him.
  10. Can someone find me the cite for that please!!!
  11. Well, clearly I am questioning my years of experience. I have a situation where the participant died and the children are the beneficiary, no spouse. The CPA instructed a distribution be made to cover some expenses with no withholding or they completed a W-4 to delay withholding until the personal returns are done. I believe they then deposited to a Trust for whatever reason. Not sure. They actually may have made the check to the Trust even. I haven't found that out yet. Regardless it's not an IRA of any kind. Can someone please provide me the mandatory taxation rules for distribution to a non-spouse beneficiary. I have read the code, seems to indicate that if it's a non-spouse it's not considered an eligible rollover distribution and therefore not subject to the mandatory 20%. However when I look at every single financial institution distribution instructions, our own that have been used and many other things, they state 20%. Help, and provide me a something to print for the correct answer meaning a code section. I must be missing something. Thanks.
  12. Tom you are correct. I just rephrased my scenario for dates. That's what I thought as well. Does anyone disagree and why? and think they should come in during the 2015 year as soon as they hit that 1000 hour mark. If so please give me a reg or something to go off.
  13. you know what, my example was wrong, duh, that's a technical term, sorry. Let me rephrase it. Same scenario, May 2014 to May 2015 doesn't work 1000 hours and we have that a lot because of all the interns theyhire BUT January 1, 2015 to July 1, 2015 he does work 1000 hours. Does he come in August 1 or does he have to wait until January 1, 2016. That makes more sense. Sorry folks.
  14. Yes please I need all I can get and somewhere of proof of why as well would be awesome.
  15. yes they did work 1000 from January through May 2015 which is why the client is saying June 1, not the following January 1 after the plan year is over. My thought is the measurement period is 12 months.