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while I have created a number of different worksheets, I never created one for that purpose. I think I would do the following. Create a dummy plan, load only the HCEs and in prior year ADP/ACP plug the average values of the NHCEs. Then run the test. Doesn't really matter what you code for plan specs, as long as all the HCEs show up. If, for example, it is the company plan, names aren't even important. in fact, even dates of birth, etc. aren't important. all you want are the HCE bodies with comp and deferral (and match if needed) it beats reinventing the wheel.

We are a small firm, 7 employees (3 pension administrators, 3 support staff and 1 owner). Basically, each administrator does everything on their cases. Support staff doe prepare and follow up on census data, prepares 1099's and does payroll processing of deposits. We are not large enough to allocate staff to one or two particular items. Years ago during one of the document restatement periods (another company), the head of my "team" split us up and had 2 people doing valuations, 2 doing documents and 2 doing plan terms and benefits. It did work well mainly because the two weakest individuals were assigned the benefits and plan term work. I don't like that approach and what we are doing works well for us. Mike

I'm not sure the EP agent is not correct. If the plan said they would get the small cashouts, then those cashouts should have occurred and not paying at the time they were due was a failure to operate the plan in accordance with its terms. Since the payouts would have occurred in the past, and would have eliminated any mortality risk after the payment date, seems like the amounts should be brought forward with interest only and then distributed.

I agree with Tom. If you know the population, just put them all into a dummy plan, make them all active and code the HCEs properly. The have Relius do it.

Just had two "turnover" orders from two federal district courts ordering the turn over of participant balances as restitution for their criminal activity. Each of those orders contained language indicate that only the net after withholding of required taxes needed to be forwarded to the clerk. So, yes, I believe taxes are withholdable from such distributions, and would think so even if the order didn't specify (not much trumps tax withholding rules). By the way, I've followed through the statutory authority specified in orders we've received and I don't believe the feds actually have authority to hit a qualified retirement plan. The orders specified the turn over of all funds not specified as exempt in a slew of statutes - which in turn references other statutes, etc., one of which is the general bankruptcy exemption list - which exempts qualified retirement plans. I've raised this issue with the prosecutors involved and they never heard of anyone ever questioning their authority. Bottom line, we complied - but in both cases the victim was the plan sponsor (and employee embezzled funds) and the "fiduciary" directed us to comply.