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Thank you Bill

Agree with all comments from @Bill Presson. I wonder if the new actuary knows this client has significant arrear payments. ? Does your service agreement help answer your question?

I would change that slightly. To recharacterize the entire ADP correction amount as catch-up, it must be less than or equal to the unused portion of the catch-up limit for the calendar year in which the plan year ends, as of the last day of the plan year. For example, if the catch-up eligible participant defers $26,000 in January 2020, you can't recharacterize any of the 4/30/2020 ADP correction as catch-up because the participant has already used up the entire 2020 catch-up limit before 4/30/20. While that kind of situation may be rare, I have seen it happen.

"I wonder if it can be charged that requiring a notarization on non-required item could be considered interference with the participant's ERISA rights?" Hi Larry - I thought of that aspect as well, but I think it is a real stretch. Maybe one of the ERISA lawyers will chime in, but I think a Fidicuary could make a pretty strong argument that such a policy is prudent in fulfilling one's fiduciary obligations under ERISA in these days of rampant identity theft.

I agree with Jeff, but in those instances there is no reason for the sponsor to start a new corporation with a new EIN doing similar work.