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Just trying to make this a bit clearer: As the cash balance plan is a defined benefit plan, if it must provide top-heavy accruals of 2%, they must be life annuities payable at NRA equal to 2% of the 5-year final average earnings. Very different from a pay credit of 2% of this year's compensation.

It has always been my understanding they want all years. They wrote the rule to clearly mean you couldn't stop at only open years. I have not seen this many years. But I have an ESOP client that just fixed a problem in their 401(k) plan via a VCP all the way back to 2003. We just helped an ESOP fix back to 2005 for problems another TPA made. I would prepare to go back as far as good records can be found. I also am not so sure this shouldn't be a VCP but if their ERISA counsel blessed self-correct go for it. I think this is a good time to go back to the ERISA counsel and have them help you determine how far back you ought to go.

Has the 2014 W-2 already been issued? If not, don't issue a corrected form, just issue a correct one.

probably the same employees who "don't need to be covered" under Obamacare because they will never work "that many hours", but then the company wants to use them to support the DB/DC plan. we want our cake and eat it too.

As I was properly corrected above, if a participant dies before their Required Beginning Date (RBD), the participant does not have to take an RMD for the year in which the participant died, regardless of the age of the participant. This person's RBD is 4/1/15, and he died before 4/1/15. No RMD for 2014. RMD's to the beneficiaries begin in the year after the participant died (2015), generally based on life expectancy rule or the 5-year rule (check the terms of the plan). The beneficiary's RMD for 2015 is paid before the rollover to the inherited IRA.