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21 years old this week! you have had to put up with my dry humor for many of them, guess you can officially have a drink now.... all kidding aside I can never say thanks enough for those who have shared their knowledge, inspired me to learn more and kept me updates on the latest pension insight and news. Many, many thanks to those I consider as good friends though I haven't seen or met them, those I know by name only (and those extra little side comments that sometimes appear) It truly does make a difference to me. (plus I even received a free coffee mug a few years ago!)

Thank you very much Tom and Belgrath! BenefitsLink has been successful only because talented professionals read it and use it. I think of this every time I see the subscriber stats to the newsletter or watch in happy amazement as sophisticated and important questions are posted to the message boards and then are answered by altruistic colleagues who contribute their time and talent towards helping out a peer. It is an awesome community, and I am just the geek who got the ball rolling back when the Interwebs were young. My wife, Lois, is an employee benefits attorney who has supercharged the operation of the newsletter especially, having jumped in with both feet when our son left the nest (she had been homeschooling him full-time). This operating simply wouldn't be what it is, but for her contributions and her encouragement to me. We've been married for almost 25 years, and it is no coincidence that BenefitsLink started under her watch and has prospered during that time. I remember well toting along a PC when we took family vacations, and dad would need to spend the morning on some dial-up connection putting together the newsletter. See http://benefitslink.com/newsletters for the archives, especially the ones from the mid-to-late 90s. Also fun is http://benefitslink.com/whatsnew/archive/ where you can find the web pages showing all of the new developments on the Internet -- one per month! For example, the DOL's Pension and Welfare Benefits Administration gets its own web page in October 1995, as does the International Foundation of Employee Benefit Plans -- http://benefitslink.com/whatsnew/archive/whatsnew.10.95.html -- the PBGC web site came online in March of 1996 -- http://benefitslink.com/whatsnew/archive/whatsnew.03.96.html -- then in September of 1996 we had to update the What's New page every week! Whew, an avalanche. It's not clear when the IRS web site came online, but it appears to have been some time in early 1995 or before. It wasn't very useful to employee benefits practitioners until later. It wasn't until September of 1995, for example, that one could find the actual text of revenue rulings and revenue procedures online, in the form of the Internal Revenue Bulletins, although I had to report that the "Only problem is they're in Adobe '.PDF' format; you need the freebie Adobe Acrobat viewer software to read them." -- http://benefitslink.com/whatsnew/archive/960915.html Unfortunately some of the links that were in the original What's New pages have been deleted -- at one time I was going through the pages and deleting any links that had gone bad. They would have been of interest looking back 20 years ago, but who knew they'd be looking back 20 years! I was only in my early 30's, and of course was immortal and would not be getting older older very soon. The birthday of the message boards appears to be September 8, 1996, so they're almost 20! Maybe we should think about how to celebrate that, coming up in less than 6 months! -- http://benefitslink.com/whatsnew/archive/960908.html Unfortunately the earliest message threads have been lost in the ether, probably due to changes that were made in the software over the years, when data migration was a much bigger deal. The first software came from a CGI/Perl book then available at many bookstores (though I didn't know it at the time); I remember shelling out $500 in 1996 dollars for a computer expert to install it for me and show how to use it! But I was so thrilled, and didn't think anything of it. Then I moved to vBulletin, then to the current IP Board by Invision Power Services. (BTW, IP Board has a new version available, which is much more user friendly and seems to have a good bit more in functionality -- I am playing with an installation on a beta server and will let you know when it's in a version that you could play with, to help determine whether it's worth the upgrade, not in monetary terms but in terms of needing to get used to some different interface. Or take a look now one of the vendor's message boards at https://invisionpower.com/forums/forum/481-product-feedback/ -- but I have recently found and am intrigued by a different vendor that provides a much simpler interface with searching features that may be as good or better -- it's called Discourse, and it's by the team that runs the very useful Stack Overflow board for software developers -- please take a look at http://try.discourse.org/ THANKS again for your notes, and THANKS so much for participating!

At its most basic level if it is a private company it is their data so they can share it as much as they like. You go the various ESOP conferences (like there was last week in MN) and you will find plenty of people that claim (with studies published in peer reviewed journals) open book management when combined with an ESOP improve profitability. Not sure if anyone has ever done research into non-employee owned companies and open book management. Their data their choice in the end.

Then as long as there is recognition of appropriate triggers which can cause them to call an ad-hoc meeting on reasonably short notice I would be comfortable with annual scheduled meetings.

1 is too few, 13 million is too many. So somewhere in between. Like jpod I don't thing there i any direct guidance on the optimal number of investments. It is left to the prudence of the Trustee's to decide.

Short answer, no. Longer answer - you need to determine applicable deadlines depending upon whether IDP or pre-approved plans, and when last restatement and approval/determination letter was done. Also See Revenue Procedure 2007-44 and 2011-49 for starters.

OH! You doesn't have to call me Johnson, now you can call me Ray, or you can call me J., ........... but you doesn't have to call me Johnson. Good ole SNL.

Nope, you can't do it ... because by the time you have procedures in place to ensure that there are no PT or 401(a)(4) issues, the employer will have had to spend money for HR work or ERISA attorney advice or probably both, and according to the OP, the employer won't spend the money. You increase participation by installing automatic enrollment or raising the match or both ... and I'll bet the employer won't spend the money for those, either.

What if the persuader is a decision-maker? Is the election to contribute freely elected? Sounds to me to be so bad on so many levels.....

I have no idea about the "for and against", but the word "persuades" stands out like a sore thumb. Who determines? Open to abuse? What if A persuades B, while simultaneously B persuades A? Any requirement that the "persuader" already be making contributions? What if a contributing EE stops, and one month later is "persuaded" to start again? And again?

You didn't say what the Trustees' roles are here? Is this a pooled plan for which they select plan investments or plan investment managers? Is this a self-directed plan and they are responsible for selecting the plan menu (rather than some other committee appointed by the Plan Sponsor)? Or, are they really nothing more than the legal title holders of plan assets who aren't responsible for doing much of anything?

Pet peeve: cites (short for citations). No cites that I'm aware of but any reasonable definition should suffice. How about the first order of business at the first meeting being the establishment of the frequency of future meetings? Such criteria as frequent enough to ensure timely decisions regarding Trustee responsibility along with the criteria for accelerating the frequency in special circumstances sounds about right to me.

That's 22 / 23 / 24. The following day, 4/9/16 was 22 / 32 / 42