mattmc82 Posted November 23, 2020 Share Posted November 23, 2020 With major recordkeepers announcing their PEP products this is going to be an instant question early on. if a stand alone safe harbor plan wants to join a PEP, do you see any issue with that plan converting into the PEP and keeping safe harbor status (for as long as all provisions are identical)? I know in the past i have heard of some payroll providers not really cooperating with these types of moves as well, requiring the plan to change providers prior to coverting. thoughts? Link to comment Share on other sites More sharing options...
Lou S. Posted November 23, 2020 Share Posted November 23, 2020 I think if you want to convert your single employer Safe Harbor Plan to a PEP Safe Harbor plan you should do it on the first day of the next Plan year. Assuming you want to keep safe harbor status for the year. Link to comment Share on other sites More sharing options...
MWeddell Posted November 24, 2020 Share Posted November 24, 2020 Given that the third party provider is changing, there will be a new call center phone number and a new website. The safe harbor notice contents must include "How to make cash or deferred elections, including any administrative requirements that apply to such elections." It seems likely to me that you'll have to provide an updated safe harbor notice at least 30 days before the crossover date but that this is a type of mid-year change that is permitted by IRS guidance. Link to comment Share on other sites More sharing options...
Alonzo Church Posted November 24, 2020 Share Posted November 24, 2020 I don't see the point of joining a PEP mid-year if you have an ongoing plan. You don't lose the compliance and filing requirements for the year. You just end up having to do them at an unexpected time. Since recordkeepers can only do so many year end transitions, this may be a complication for PEP plans going forward. Link to comment Share on other sites More sharing options...
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