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I know the language may say that, but good luck getting an auditor to agree. I don't think it stands up based upon official guidance. If you ask Relius, I expect they might agree. This language is nice to hopefully prod a participant to pay attention, but I would not want to try to hang my hat on it if trying to defend the employer's failure. (Yes, if audited, you'd use that 'cause it's all you have got, but I'm not confident the auditor would agree. But hey, I've seen some fairly lenient audits, so you never know. I just wouldn't decide NOT to correct based upon this language.)

No, I already have a lot of credits. The seminar is on cash balance plans from Datair and it is worth 20 hours - still a great deal. And that puts me at over 72 hours with yet a year to go in my cycle. All I am lacking is 4 hrs ethics, and so plan to still do that.

You would, but there is a reality disconnect in that many insurers will not write an annuity for a small single premium. Some of them define small as anything less than $30k.