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I wouldn't say to clients that documents are "legal" work, as that my imply that lawyers are involved.

Is anyone (TPAs I mean) concerned that after PEPs are up and running it won't matter what we call ourselves, or do you think a small TPA firm will still be relevant? Just curious. Keeps me up at night sometimes.

I have railed against the use of TPA to describe what we do since time immemorial. I have lost that argument, but I still don't refer to ourselves as a TPA and I correct anyone who uses that term with us. We use the phrase "retirement plan service provider" or just plain "service provider". Because, I ain't a THIRD PARTY anything! We're a FIRST PARTY with our clients. I ask clients if they would refer to their atty or acct as a "third party atty or acct". Same thing with us. We represent the client directly, not as a third party. The phrase TPA came from the health insurance industry where there really is a "party of the third part" which is different than the party of the first part (the client) and the party of the second part (the insurance company) who then go out and hire a true THIRD PARTY to do some work on their behalf. What a mistake our industry has made and continues to make.

At least people don't say "Oh - you're in insurance?" like they used to back in the day when I started in retirement plans and said I worked for a TPA ?!

It does address this, but there are some additional requirements. Section 4F. If you make a payment after the 2020 tax return due date, that payment will first have to satisfy the 2021 repayment amount. Any payment in excess of the amount includible in income for 2021 can be applied to 2020 and/or 2022.

Yes

There is no connection between the ordinary income from a distribution from a traditional IRA and the deduction for capital losses except that they each contribute in their own respects to taxable income -- increasing it or reducing it. You can look at the deduction as an offset to the income, but you could be fooling yourself by missing the big picture and the possible effects of other tax phenomena, such as rules relating to quarterly tax payments.