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Yes, it is required - if applicable. So we do it quarterly for plans with brokerage accounts or where otherwise the statements are inadequate. DOL FAB 2006-03. Also discussed in ASPPA asap 07-08 (brilliantly written ). Of course we are still waiting for the sample language from the DOL that was required to be provided within one year of PPA ('06).

What part of 0.5 times zero implies differently?

I asked you not to ask why.

I wish a plan’s sponsor would ask me to help design and document its plan. Nowadays, that happens with governmental plans and plans for select-group executives, but on plans that could fit the IRS’s § 401(a) and § 403(b) “preapproved” regimes only for mega plans. Luke Bailey, thank you for your idea of writing (or interpreting) a plan to treat a partner as meeting a last-day allocation condition if she then was available to perform services.

Bill- You crack me up, reminding me of the days when I worked Pentabs support and someone called and asked why the compensation for the HCEs was getting reduced. The old family 'aggravation' rules - somehow the guy coded the system as family members but didn't know the rules that it was combined comp of all family members that was capped at the comp limit. and his response was somewhat similar to yours "I must have been asleep when they came out with that rule"

the DOL approved such a design in their PTE 2000-10A to Hugh Janow in 2000-cf DOL PTE 2000-10A The clients (with hindsight) probably wished they hadn't The Partnership's assets were to be invested by Bernard L. Madoff Investment Securities-an unrelated Investment Advisor- that made them Plaintiffs

I think if someone had earned income and was still a partner at the end of the year I would consider them as employed.