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It doesn't matter until it matters. And it probably won't ever matter in this case. That doesn't make it a good idea in other situations.

If it was me, I would make it a three source split going forward: 1. Pre-2020 deferral and profit sharing 2. Deferral 3. Profit Sharing You can always explain why you can't track pre 2020 contribution, but you should track the contributions you can.

Question - what have you been getting for asset statements/information in prior years in order to do the administration? Typically the TPA would have this information. It's a starting point. As far as a Successor Trustee being appointed, the plan document should provide specific information on how this is handled, or it may require a court-appointed successor. You need to have the wife contact an ERISA attorney for assistance. As a TPA, chances are you can only help point her in the right direction. Also very important for her to contact the institution where the assets are held (once you tell her where that is) to have her explain the situation, and ask them what THEY need in order to change Trustees, release information, etc., etc. - and make sure she gets in in writing. The ERISA attorney should be able to assist her with this. Other things may occur depending upon specific facts and circumstances.

Dennis G., generally paid leave is W-2 wages and will be countable for purposes of Section 415 and also included in compensation in the plan's definition of compensation.

Long time reader - first time post. We have a profit sharing plan that terminated and is in the process of distributing assets. Unsurprisingly, there are several unresponsive participants, as well as one missing participant. We are reviewing options for disposition of those account balances. We have completed the IRS/DOL requirements for searching, sending certified letters, etc. Under the DOL safe harbor, the preferred method of distribution is to roll over account balances to IRAs the employer establishes for the missing/unresponsive participants. In the past, we have used Millenium Trust (MT) for such rollovers. In 2017, the PBGC expanded its missing participants program to include defined contribution plans. We are considering whether this is a good or better option than IRA rollovers and are wondering if anyone has used the PBGC program for a defined contribution plan. If you have used the program, do you have any thoughts on or experience with their process? And why did you choose to use it instead of IRA rollovers? If you haven't used it, did you consider it? What were your reasons for not using it? Here are some pros and cons we've considered: IRA rollover - Pros: well-known and well-used provider, purports to comply with ERISA safe harbor, participant can contact IRA provider and choose among investment alternatives or roll over to another plan/IRA Cons: must send notice to participants at least 30 days before transfer, not sure how safe the safe harbor is PBGC program - Pros: no prior notice required (probably a good idea to notify participants, but not necessarily before transfer) Cons: program is new and unknown, there's only one investment option for participants (participant would have to take distribution, presumably in cash, and roll over to IRA to invest differently and also come up with the mandatory withholding amount out of the participant's own funds if the participant wanted to roll the entire amount), no rollover option (as far as we can tell) Another consideration is fees. MT charges fees to the participant, while the PBGC program charges fees to the plan sponsor (and the PBGC fee is lower than the IRA fees). Presumably, a participant could argue that the plan sponsor chose the IRA provider because the plan sponsor didn't have to pay any of the fees. But the plan sponsor could argue that they chose the IRA provider because it satisfied the DOL's safe harbor. Thoughts on pros and cons?

Not true.How about everybody in their own group.

If your plan document provides for discretionary contributions allocated in a discretionary manner based on criteria broad enough to include (e.g., "any basis acceptable to the employer,"), sure this is OK.