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Wow, I wish all of our employers would do this. When I think of the headaches and errors that would be prevented... But in answer to your question, no, I have no suggestions. It is possible, depending upon how it is presented at the meeting with the employee/HR, that an auto escalation might improve deferral percentages. "You deferred 3% last year. This year it automatically goes to 4% unless you elect otherwise. Sign here." It might overcome a certain amount of inertia.

Not that much involved with controlled group issues, but husband owns one company, wife owns another unrelated company, and there are minor children = controlled group. Ownership of each company is imputed to the minor children. Do I have that right?

It is at least theoretically possible that the TPA isn't charging any more for the regular 5500 than they would charge for the SF.

I check my CPE for ERPA under the IRS PTIN system. All of your credits over the years are reported there. https://rpr.irs.gov/datamart/mainMenuUSIRS.do Good Luck!

Are you expecting logic from the folks at Treasury?

The participant, having separated from service, was treated as having reached his or her Required Beginning Date with respect to the plan. I wonder if it is implied that, having reached the Required Beginning Date, future RMDs must be paid. There is nothing in the law, regulations, or plan document addressing unreaching one's Required Beginning Date, is there? There would have to be something like that to relieve the participant of being paid RMDs as a result of reemployment. I suspect it would not be acceptable.

Unless something has changed since the last time I looked at this, the regs are silent on this issue. I believe IRS informal guidance (possibly from the podium at an ASPPA conference) was that the safest course was to continue the RMDs that had begun. I do not know if there have been further comments on this issue.

K2, The regs should help with your question. For the initial plan year of employment, eligibility is determined by expected hours of service. For later plan years, eligibility is determined by actual hours in the prior plan year. For your question in post #5, the person is not a participant for the year ended 6/30/16 because he/she was not expected to work 1,000 hours in his/her first 12 months. When he/she did work 1,000 hours in the plan year ending 6/30/2016, he/she became eligible 7/1/16. I suspect the article you quote is saying that the person doesn't become eligible mid-year when they reach 1,000 hours during the year. But, rather, they become eligible at the beginning of the following year.

^ true. And sometimes, firms just prepare the same form as the previous year "because that's the way it's always been done."

Since I'm in such a good mood this morning, write about the primary effects of requiring ERISA fiduciary rules to apply to elected and appointed government officials and their staffs. Yah, I live in a dream world sometimes, but it is a serious suggestion and should make for interesting reading.

Wonder if that doctor will slow down on tranquilizer prescriptions and in stead recommend a fifth of vodka to calm the nerves of their patients?

No. If he's covered by a 401(k) plan he's considered covered whether or not he can make a full contribution to the 401(k). He falls under whatever rules apply to a person covered by a plan and deductions are then bases on MAGI.

We initially did it to avoid the angry phone calls after the fact saying "what the heck is this fee?" knowing of course that no one will ever read a fee disclosure. But what we are doing now is putting a simple statement - please note fees may apply, and take a look at the fee disclosure.

I know what is going on here. The Plan is unprofitable and they actually hope you will leave.

While what Lou suggests *may* be the cleanest, keep in mind that 1) upon termination, there will be a run off of assets, and 2) the "start-up" plans will be less attractive to service providers, possibly limiting choice of service providers and increasing costs. I always suggest spinning off each half to separate plans assumed by the new entities (unless, of course, there are "issues" that would carry over).