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If the "solo" participant is near or over age 70 at plan inception, a vesting schedule... like 3-year cliff, will delay RMD's. FWIW

Employer A was misinformed. There is no requirement under the ACA regarding eligibility for FSAs. In fact, not permitting these part-timers to participate may implicate the Section 125 nondiscrimination tests depending on the demographics of the employee population.

In WS36, Sue Diehl said the 403(b) opinion letters are expected to be sent out in the Spring of 2017. I took that as probably the end of March or in April.

Yes. To me she is saying that the medical eligibility and the fsa eligibility are the same, which is usual.

I asked the provider of the docs and they said they took care of this, any updates are filed appropriately and both the participant and myself would be advised of any changes. Not exactly the case - I was asking (sorry for not being clear) if I run it on a custodial platform what additional measures should I take to ensure that it is all running properly. What I've noticed is that some providers (EG Vanguard) split the transactions into EE/ER at time of contribution whereas others (TD Ameritrade) do not. I just wanted to make sure that if we were with a custodian like TD (using their model prototype plan that they update) that contributions were tracked properly. Well... I had one recent solo 401k plan where the sole participant set up 2 TD Ameritrade accounts... one to hold his rollover, and the other to hold his 401k deferrals. And both TD accounts were linked so a consolidated statement was also available. So even with TD, you should be able to set up 2 TD accounts... one for EE, one for ER, and also get a consolidated statement. And this may be even better than Vanguard, as the EE and ER money can be invested differently.

But I think a lot of the advice here boils down to this: You may think you are merely going down a small rabbit hole by record keeping the funds. But you may find yourself waist deep in a warren of rules and contingencies you weren't prepared for. Some tunnels are straight forward, but some are winding and complex and lead to further winding and complex tunnels.

Bottom line: can you track the contributions on a platform that doesn't separate them? Of course. It happens all the time with pooled plans. The plan document should tell you when and how to allocate the earnings. You can build a spreadsheet to calculate those earnings. You (someone) will need to furnish the participants with a statement at least annually with a breakdown by money type of their account.

A QRP has to do with DB Plans. It's a way to mitigate the tax on reversion of assets to the ER, by placing the extra assets in a DC plan. It has nothing to do with terminating a 401(k) plan.

maybe I am missing something. I have a 401k plan. I am going to terminate and put in a new 401k plan. why not just amend the old plan, or switch asset providers if that is the goal?

Do they get fries with that? Thanks for adding value to the discussion. No offense was intended. I think that hidden within this statement is really the underlying aspect of this whole discussion. What is the perceived value of something? For some, my original post may have been of value because it added some levity to the conversation. For others, it may have added value to the discussion by highlighting the possible dichotomy of being able to provide services that include everything while seeking for insight on some fairly routine procedures for pension professionals. For still others, it added no value because it did not address a desired question or was perceived as a belittling comment. Similarly, some may see little value in paying fees for certain services because they prefer to the take the associated risks or assume little or no risk will exist. Others see a greater value in paying the fees to a seasoned professional due to the peace of mind they will have. To each his own.

I am going to make a different observation from the CPA and TPA points of view. I am simply an employer (myself) of a one-participant 401k plan. I appreciate the knowledge and experience of the members of this forum. It is primarily intended for professionals, but unlike some other professional forums, they are willing to share with everyone. Which I find extremely helpful, because as has been pointed out one-participant 401k plans are 99.9% the same as full blown plans. With that said, I think the TPA viewpoints expressed in this thread are a little over reactive. It seems like the majority of replies here are assuming that we a talking about investment only accounts in conjunction with separate plan documents with no support from the financial institution. These absolutely require a TPA. But... From the OP's posts, I rather think we are talking about standard protype backed plans marketed by mainstream providers. Therefore, I am assuming we are talking about a standard prototype one-participant plans from a financial institution. Even the main stream providers differ in the level of services they provide. Some only act as custodian, leaving the the trustee and administrator choice to the employer. Some extend that to provide trustee services. They vary in the level of record keeping they provide. They all leave the administrator choice to the employer. Sure the principal can specify a third party administrator (and if necessary trustee), but the vast majority of such one-participant plans are operated with the principal acting possibly as trustee, full/partial record keeper, and/or full/partial administrator. We can argue whether that is a good idea or not. Unfortunately, the providers market these plans as nothing more than a SEP IRA with the possibility to increase your contributions, by adding employee deferrals if you haven't otherwise used up that space. The reality is that most people with one-participant 401k plans operate in blissful ignorance. So a knowledgeable CPA can provide useful services in contribution calculations, record keeping, and administrative advice. This is certainly better than what currently happens with the majority of one-participant sponsors being relatively clueless of what lies beneath the surface of their plans. However, my experience and anecdotal evidence leads one to conclude that many CPAs are also clueless in even the most basic issues. As a corollary, there have been a lot of inferences based on facts not in evidence. Given my assumption. 1. Every provider I am familiar with; monitors LRMs revises/restates the plan document when required. All that is required by the administrator is to timely provide amendment certification and complete a new adoption agreement in a timely basis. I have only needed to do this twice in the last dozen years. 2. Yes, controlled groups and affiliated service groups are complex and I would consult a retirement plans professional. However, all that is necessary is to know the basics to know you need assistance when the circumstances arise. 3. Most providers track contributions and earnings by account type. Some will track 402g and 415c limits. 4. Unless I am mistaken I don't believe the issue of in-service distribution prior to 59.5 has anything to do with pre-tax vs. post-tax. My understanding is that all deferrals and their earnings regardless of type and non-vested employer contributions can not be withdrawn prior to 59.5 even if the plan allows in-service distributions. Vested employer (pre-tax) contributions and earnings can be withdrawn prior to 59.5. 5. All one-participant employer contributions are fully vested. 6. There is no anti-discrimination testing. So my opinion is this. If and only if we are talking about standard prototype plans at a major provider, there is no reason why the OP can't provide value add to their clients on these plans. At some level this is not that much different than the services a CPA provides on other areas of tax law. Provided the CPA acquires the necessary knowledge. The plain fact is that plan sponsors are simply not going engage a TPA for a mainstream provider one-participant 401k. At the end of the day are they better off with the assistance of a reasonably knowledgeable CPA or flying solo?

Wow. Well, I'll just say that in my opinion, anyone for whom $300.00 is too much to pay for qualified plan administration should NOT, NOT, NOT have a qualified plan. I've been paid a lot of money by these "do it yourself" plans when filing under VCP, etc., to correct the problems. I'm also curious - how do YOU get paid on all of this? I presume you are not a charitable organization. Are you a broker, receiving commissions, or a CPA? However, that's really none of my business, so I'm not offended if you decline to answer that. Anyway, if you intend to go down this road, I wish you the best of luck. I think others here have already given you sufficient advice, and if you proceed, do it with open eyes (because the clients will most definitely blame you when something goes wrong) and make sure your E&O is paid up.

A good example of why, when asked, "How long should we keep plan records?" we always tell them FOREVER!