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Thanks, Bill. I agree with your assessment of PEPs but their proponents are starting to push them as a cost saving/ risk shifting measure.

There was a law a while back that explicitly permits in-plan Roth conversions of amounts which would otherwise not be distributable. The converted account remains subject to whatever withdrawal restrictions applied before the conversion. See Notice 2013-74. This is optional of course; plans are free to restrict in-plan Roth conversions to amounts that would be otherwise eligible for a distribution.

I recommend you read the instructions on the site. The definitions are under the "Glossary" section. Recovery Date - The date that the Principal Amount is restored to the plan. Final Payment Date - The date on which Lost Earnings is paid to the Plan, if later than the Recovery Date.

However, only the pre-tax assets can be rolled over from a traditional IRA to a qualified plan pre-tax account. The prohibition against the rollover of non-deductible basis is intended to preserve the integrity of the qualified plan pre-tax account. I'm not sure what point you are trying to make.

Possibly, Mike refers to IRC 7525?

You are (probably) correct. I agree with you, but there are some people who say that once you file your return by your regular due date, any extension received is null and void. I don't agree, but I prefer that under normal conditions client wait until a day AFTER the regular due date and then file under their extension so now they clearly do have to the end of the extension period to add more money (and file an amended return). What is different here is that IRS extended the original due date, so I think you are not operating under an actual extension, but a moving of the regular due date, and therefore you are still BEFORE your regular filing date and you can put more money in and file the amended return, but you are still not on extension. Short answer: I agree with you.

Gotta keep track of pre and post tax monies, subaccount label is irrelevant.

This has been thought of before, and implemented in varying fashions. I think a big problem with the concept is that it does not fit within either the classic ERISA 404(c)(1)(A) self-directed or the "new" 404(c)(5) default investment safe harbors.

Without discussing IF this should be done, there are two ways this can be handled. The first way is through the use of fund models, that are a "Fund of Funds" which are available in the plan. The available software for this is clunky and we have a few plans using this approach (in conjunction with allowing participants to choose from the underlying funds), but we will not be adding any new plans. The other way is through the use of a "fund" setup on the trading house platform. The investment advisor chooses the underlying funds and does the trading, and the share prices are reported back as it's own CUSIP. MidAtlantic calls it ModelXchange and Matrix uses Model Toolkit. The underlying investments in these models are not necessarily investment alternatives available in the plan. The plans have a variety of other investment options available, including the model funds. There is some additional costs to run the models, but we have several plans that use them. It also comes down to what the broker-dealer of the RIA will allow them to do too. The RIA also needs to be involved in what is reported on the plan's 404a-5 notice, etc. There is a lot of liability for the RIA so expect to pay their fees accordingly. I do not believe that a plan sponsor is able to run these funds directly.

Literally, she wrote the book.

Larry is tired. Frankly, after all the effort he has spent on PPP this last week I'm surprised he isn't sleeping. :-) I read the OP as saying that he happens to have an existing plan that is balance forward, to date. They want to move to individually directed with daily recordkeeping with a twist. Instead of providing participants with a menu of mutual funds he wants to create a set of investment options where each option is professionally crafted and managed by an investment professional. Setting aside the fact that this design is very difficult to implement (from a fiduciary perspective) there is nothing wrong with the concept. I would be surprised if many of the recordkeepers in today's market can accommodate this construct. Instead, a big investment house is more likely to have created proprietary funds that are close. In short, the OP is trying to re-invent something which already exists. And if they were the size of, say, Boeing, they might just find an investment house/recordkeeper platform willing to create exactly what he is looking for. Otherwise, the fiduciary risk to implement this on his own is off the charts and makes no sense in today's marketplace. I'd be interested in @Peter Gulia's take on the fiduciary issue.

By definition, that is NOT a balance forward plan; you specifically say it would be updated daily. What are you really trying to ask? What you are describing IS an individually directed plan with participant selection of investments. Selecting from different offered investment options IS participants directing their investments. Your premise regarding balance forward makes not sense. Any platform should be able to do this; I of course would not think of recommending such an option but that's a whole other discussion and not for this thread.