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I agree with the above. That said, I have been able to get the DOL to accept a combination of their calculator and a spreadsheet. It has probably been 5 years since I did it that way so I'm not sure if they would still accept it, but it may be worth a try. For example, lets say you have 100 participants who deferred and you have one late payroll. Rather than doing 100 individual calculations,you do one earnings calculation on the entire amount and use a spreadsheet to distribute the lost earnings based on each participants "share" of the late deposit. The result can be a little different from one by one calculations due to rounding, but it is minimal and to be on the safe side you can always round up so that a participant will get a fraction of a cent more rather than less.

No, you can't do that. Whatever eligibility requirements they select apply to all employees. The Form 8905-SEP or document used to establish the SEP should clearly say that. We have a huge volume of rules in ERISA and the Internal Revenue Code intended to prevent the type of discrimination you are asking about.

I think he means "You want to establish less restrictive eligibility requirements for owners and officers but apply the more restrictive normal eligibility requirements to everyone else? You are kidding, right?" Mike, is that what you meant?

You are kidding, right?

Is 2017 a distribution calendar year with respect to this participant? Whoever is arguing for no RMD needs to read he 401(a)(9) regs again and again until they can answer this question. Once they can answer this question they need to agree to the required RMD.