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I worked for a large firm that had IT people that allowed us to program based on the file specs a FIRE file for 1099-R many years ago. So I am assuming you could do that with the 8955-SSA. I do recall it helped that I had the help of an IT person and I have a degree in Accounting and IT as it would be overwhelming for a novice. I agree if you can find a friendly TPA who has the software you feel comfortable working with you might be easiest.

To file electronically, you have to have software or a service provider that will create the file in the proper format. They may be better off finding a TPA to do this for them.

I agree. I think the only time you're required to include compensation while not a participant (other than when the plan says to) is for top heavy.

I work for a different company than those you mention - but we have a very LARGE book of SMALL plans. We have no plans to undo that which we implemented to be compliant with the "Rule." There may be some changes, but throughout the process and the litigation, our stance has been it is the "right thing to do." In some cases we changed processes to not be a fiduciary, and in others we decided to become a fiduciary (our distribution/rollover people are licensed and fiduciaries).

It seems like they are changing from 0% to something other than 0% and can do so "weekly".

Thanks, Peter, for the citation. I fully support the "spouse as automatic beneficiary unless spouse waives" law/concept, but when you see the actual statutory language and the whole QJSA/QPSA stuff, with numerous amendments, one may be tempted to agree with Mr. Bumble, "The law is a ass..." As a layman, seems like it could have been made more sensible and streamlined. For example, it never made any sense to me why a profit sharing plan should be treated differently, for these purposes, than a pension plan. On the other hand, if ERISA, the IRC, and all associated regulations/guidance were as simple as they ought to be, we'd all be out selling matchsticks or something, so I should keep my yap shut and not gripe!