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I agree, but if you utilize the special consolidation rule you will not be sending out a notice of availability for every notice. You would get annual notice that you can go to this website to view and download XYZ notices. The way I have seen this interpreted, you will not get a notice when each one is updated/posted, you would just get an annual notice that this is where you go to get this group of notices. This will probably get some attention during the comment period though, so who knows if it will stay like this for the final rule. § 2520.104b–31(i) Special rule for consolidation of certain notices of internet availability. Notwithstanding the requirements in paragraphs (d)(4)(ii) and (iii) of this section, an administrator may furnish one notice of internet availability that incorporates or combines the content required by paragraph (d)(3) of this section with respect to one or more of the following covered documents: (1) A summary plan description, as required pursuant to section 104(a) of the Act; (2) A summary of material modification, as required pursuant to section 104(a) of the Act; (3) A summary annual report, as required pursuant to section 104(b)(3) of the Act; (4) An annual funding notice, as required pursuant to section 101(f) of the Act; (5) An investment-related disclosure, as required pursuant to 29 CFR 2550.404a–5(d); (6) A qualified default investment alternative notice, as required pursuant to section 404(c)(5)(B) of the Act; and (7) A pension benefit statement, as required pursuant to section 105(a) of the Act.

No problem there. ? But seriously, what is the origin/backstory of this proposal?

It happens. (hope I spelled that correctly)

My outline on self-employment income determination has circled the globe at least 10 times! ? If you send me an EMAIL to larrystarr@qpc-inc.com I will be happy to send you the outline which will answer ALL your questions. There are a number of additional steps that must be considered (for example, unreimbursed partnership expenses, Sec. 179 deductions, and certain oil and gas partnership issues) so it is not as simple as just pulling the numbers off the K-1.

Eligibility computation period begins the date employee first performs an Hour of Service, regardless of the effective date of the Plan, so by 12/31/2015 both Joe and Sue completed a year of eligibility service. Did they lose that service due to break in service rules? Clearly not. Were they employed on their first entry date following completion of eligibility requirements? Yes, both employed on 1/1/2020. Plan provisions should be fairly clear on this as well as vesting.