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"Actual knowledge to the contrary"


austin3515
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Every conversation with a client regarding loans and withdrawals needs to start by reminding them that the new allowances are not mandatory.  Since they are voluntary they can be fully implemented or partially implemented.  The fly in the ointment of partial implementation is that there is concern regarding the document provisions that will be incorporated into the plan by the end of 2022.  Not a lot of concern, but enough to mention it to clients.

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20 minutes ago, Mike Preston said:

Every conversation with a client regarding loans and withdrawals needs to start by reminding them that the new allowances are not mandatory.  Since they are voluntary they can be fully implemented or partially implemented.  The fly in the ointment of partial implementation is that there is concern regarding the document provisions that will be incorporated into the plan by the end of 2022.  Not a lot of concern, but enough to mention it to clients.

Word of caution - not all providers took the time to program in all that flexibility.  And who can blame them they are going to hit the delete key on all this programming in 8 months.  There are more than one where if your option is to add these full tilt or not at all and that's that.

Austin Powers, CPA, QPA, ERPA

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8 hours ago, Luke Bailey said:

BTW Larry, yesterday evening I Googled this. If you are interested in a more inclusive, contemporary take, you can check this out: https://www.merriam-webster.com/words-at-play/beg-the-question

Good job Luke. I am very aware of that definition; my friend (now deceased) was a senior official at Merriam Webster (they are a Springfield, MA company) and was the editor in chief of the MW Collegiate Dictionary. He and I once presented a paper to our regular group regarding misuse of certain phrases, and we covered "begging the question".  The fix is so easy: just say "raises the question" instead and everyone will be happy and the individual will no longer raise the ire of those of us who react to "beg the question" when used incorrectly like fingernails on the chalkboard!!!! 

Lawrence C. Starr, FLMI, CLU, CEBS, CPC, ChFC, EA, ATA, QPFC
President
Qualified Plan Consultants, Inc.
46 Daggett Drive
West Springfield, MA 01089
413-736-2066
larrystarr@qpc-inc.com

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11 hours ago, RatherBeGolfing said:

just a guess on my part, but the lower you get in cost/fees, you are also likely to get less flexibility for something like this. 

Well Empower was one, and it was more closely related to their desire to be the first to  market.  Not sure what Fidelity did.  Maybe Empower will add that enhancement, I definitely have clients who have been asking for it.

Austin Powers, CPA, QPA, ERPA

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11 hours ago, Larry Starr said:

Good job Luke. I am very aware of that definition; my friend (now deceased) was a senior official at Merriam Webster (they are a Springfield, MA company) and was the editor in chief of the MW Collegiate Dictionary. He and I once presented a paper to our regular group regarding misuse of certain phrases, and we covered "begging the question".  The fix is so easy: just say "raises the question" instead and everyone will be happy and the individual will no longer raise the ire of those of us who react to "beg the question" when used incorrectly like fingernails on the chalkboard!!!! 

The funny thing is that incorrect usage of certain words or phrases can become so common that they are accepted as alternative.  

I don't know how common it is for schools to offer formal logic anymore, but it was one of the best courses I took as an undergrad.

 

 

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image.png.0e0eb537031beaf1e2fdf9cce632d199.png

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.
corey@pppc.co

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15 hours ago, Larry Starr said:

Good job Luke. I am very aware of that definition; my friend (now deceased) was a senior official at Merriam Webster (they are a Springfield, MA company) and was the editor in chief of the MW Collegiate Dictionary. He and I once presented a paper to our regular group regarding misuse of certain phrases, and we covered "begging the question".  The fix is so easy: just say "raises the question" instead and everyone will be happy and the individual will no longer raise the ire of those of us who react to "beg the question" when used incorrectly like fingernails on the chalkboard!!!! 

Yes. And for the Aristotelian usage that you advocate, Larry, one might better say "Assume the premise." But anyway, I will live and let live on both since they are in the vernacular.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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18 hours ago, austin3515 said:

Word of caution - not all providers took the time to program in all that flexibility.  And who can blame them they are going to hit the delete key on all this programming in 8 months.  There are more than one where if your option is to add these full tilt or not at all and that's that.

Ultimately, the plan sponsor is in control of its document, and in theory an employer could change its policy over time, as conditions on the ground emerge, as long as the changes are not discriminatory. That's the beauty of adopting a policy, not a plan amendment. However, ultimately the plan sponsor's amendment (generally by the end of 2022) should track what it did, so if that was not uniform over time, it needs to keep a record of what it did at various times.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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Credit for the comic goes to Ryan North of Dinosaur Comics.

Hope I can bring a little levity to everyone's Friday :)

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.
corey@pppc.co

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1 hour ago, Luke Bailey said:

Ultimately, the plan sponsor is in control of its document, and in theory an employer could change its policy over time, as conditions on the ground emerge, as long as the changes are not discriminatory. That's the beauty of adopting a policy, not a plan amendment. However, ultimately the plan sponsor's amendment (generally by the end of 2022) should track what it did, so if that was not uniform over time, it needs to keep a record of what it did at various times.

One of the most important lessons I ever learned was don;'t fight the system.  No good will ever come of it.

Austin Powers, CPA, QPA, ERPA

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