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My understanding is if the entity is a partnership and has a tax-year ending 12/31, the unextended deadline to file the 2019 return is 3/15/2020, and thus it doesn't qualify for the delayed 7/15/2020 due date.

Two sources to review as yes Retiree HRA or Retirement HRA, Retiree-only HRAs: An ACA-friendly benefits strategy ... www.rehmann.com › resources-insights › business-wisdom-2 › item But if you have a retiree-only HRA, the caps apply to only the amounts you reimburse in those accounts. For example, suppose that, with a regular retiree health ... 201805002 - Internal Revenue Service www.irs.gov › pub › irs-wd PDF Feb 2, 2018 - Taxpayer adopted a retiree-only Health Reimbursement Account Plan (“Retiree HRA”), effective the beginning of Year 2. The Retiree HRA ... sources to review as yes Retire HRA

Doc - you are correct about CARES 3608(b). However the act says that the plan "may elect" to treat the 2019 AFTAP as the 2020 AFTAP - it is not required. What David is saying, and please correct me if I am misinterpreting, is could/should a plan sponsor instruct the actuary not to certify the AFTAP for 2020, and also not elect to apply CARES 3608(b), thereby causing the plan to have a presumed AFTAP <60% as of October 1, 2020 (assuming calendar year). One effect of having an AFTAP less than 60% is that the plan is not permitted to pay lump sum benefits. Not having to pay lump sums may be advantageous to the plan's financial health after a large drop in the value of plan assets. I feel like this could be construed as administrator discretion in the availability of a form of benefit. If one of my clients asked me if they could do this, I would advise against it.

If you read the applicable sections of the ERISA Outline Book that would be a good start. There actually is not nearly as much to know as in the 401k space, but if you don't know even one of the important things to know, then you can really cause trouble. Who can be eligible and the taxation rules just to name two that come to mind.

In addition to the TGPC, ASPPA has a CPC module about nonqualified plans. It's not specific to 457(f) plans but they are on the syllabus. Derrin Watson has a 457 book available on erisapedia.com; it is, like everything the man writes, excellent. But it is more of a reference manual than a training resource.

ESI2015, by "nonqualified 457 plan," you mean 457(f)?

You may want to look at NTSA (sister company to ASPPA) and the TGPC designation.

I would agree the ESOP Association seems to have be more geared towards the industry professional vs the NCEO which clearly has an employee owned company as more of its goal. I will say that ESOPs are a real specialty to themselves. I am not trying to be mean but I cringe whenever we get a client whose former TPA was a 401(k) shop that was doing the ESOP work as a courtesy to their 401(k) client. They have a very high VCP filing record after we start to dig into them. If you want to learn I would suggest you find out which ESOP Association chapter you live in. If you live in the US you live in a chapter's territory. You can find out when they are having local conferences. They all have at least 2/year. I would think about attending those. The chapter conferences are less expensive and since it is broken down into territories you might not incur as large travel costs. They all have good breakout sessions. If you just can't make a conference if you join the NCEO they have a 1 hour webinar most weeks of the year that is free to members. They happen around lunch time if you are in the Eastern or Central time zones. If you are west of that it is still morning when they happen. At one hour they aren't going to be super detail but you can get a good idea of the issues.

Plan provisions can mandate distributions at retirement age. If it does, and the person has reached normal retirement age, and the person is missing, the plan can force out the monies.

Maybe this? IRS Notice 2020-23: "For an Affected Taxpayer with respect to Specified Filing and Payment Obligations, the due date for filing Specified Forms and making Specified Payments is automatically postponed to July 15, 2020.... This relief is automatic ... The Secretary of the Treasury has also determined that any person performing a time-sensitive action listed in ... Revenue Procedure 2018-58 ... which is due to be performed on or after April 1, 2020, and before July 15, 2020 (Specified Time-Sensitive Action), is an Affected Taxpayer." Rev. Proc. 2018-58 -- See page 48

IRS Notice 2020-23: "For an Affected Taxpayer with respect to Specified Filing and Payment Obligations, the due date for filing Specified Forms and making Specified Payments is automatically postponed to July 15, 2020.... This relief is automatic ... The Secretary of the Treasury has also determined that any person performing a time-sensitive action listed in ... Revenue Procedure 2018-58 ... which is due to be performed on or after April 1, 2020, and before July 15, 2020 (Specified Time-Sensitive Action), is an Affected Taxpayer." Rev. Proc. 2018-58 -- See page 57

Trailing question answer: yes. ANY plan is allowed for repaying the distribution, including IRAs. Last question: if it's a CVD distribution, then yes, they can put it back if the plan allows rollover contributions. Or they can put it in another plan (like a personal IRA).

If the plan is allowing for the payout, it can be a CVD (Corona Virus Distribution) regardless of the reason. As to the distribution taken, treat it as a CVD and it can be put back (there is that 3 year rule that now applies to his distribution). It can't be an RMD because those (legally) don't exist for 2020. I don't understand your third question. There are no RMDs this year AND the rule is now 72; what are you asking?

Yes they can, and the dirty little secret is they have been doing it for years. I have provided a link to Tenet Hospital policy for your review. https://www.tenethealth.com/docs/default-source/provided-without-financial-incentives/policy---comp-rcc_4-55_payment_of_patient_insurance_premiums.pdf?sfvrsn=740a2db7_4

They sell "401(k) leads" to financial advisors. They collect the data, package it in a report, and sell it as a lead. Im sure they do some sort of review so they can say they provided a service, but their game is selling access to the plan.

We had a sponsor receive one of these calls a few months back, and the caller was kind enough to leave a voicemail which the sponsor forwarded to us. I don't know if I'd use the word "scam" since I'm sure they're providing a real service (albeit one of questionable value) but it definitely feels like a sleazy pitch. They're intentionally being vague about what fiduciaries are required to do with respect to reviewing their plan, and suggesting that their service would meet these requirements if performed regularly -- the caller in our case stated that this review is required to be performed every 6-12 months for all plans. I'm not familiar with the group and for all I know they do great work. But the message we heard didn't make a good impression on the sponsor or on us.