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No, it isn't still alive. Just a copy on my "friends" standalone PC and 20+ years worth of ESOP history (and this old dog doesn't want to learn new tricks).

I'm absolutely NOT disagreeing with this; in fact, I agree. But to relate ancient experience... In a prior life some 20-odd years ago, wen I worked for a company that had an Enrolled Actuary and the EA always attended the EA annual convention, this issue came up. At the time, the IRS representative opined (of course, this was unofficial) that it was ok establish the plan on, say, 1/1 even though the employer didn't exist until later. Back then, all plans other than standardized were submitted for determination letters, and we had plans like this approved with nary a question. Haven't done this for a long time, and wouldn't do it now without some sort of clear guidance.

We used FDP back in the day. It was morphed over to Relius (actually Quantech first but that's another story). Anyway - I'm not sure I am chuckling, it's more scary I think. Why on earth is someone running a val on FDP and the DOS version no less? Not to mention the myriad of changes that have happened in the Regs since then.....

If I were the fiduciary in this case, I would invest in the manner of a prudent person familiar with such matters. Furthermore I would diversify the investments in order to reduce the risk of a large loss. For real though, there is no reason that the ages of the participants need to dictate the plan's investment strategy. Assuming that the plan provides that gains and losses will be allocated to each participant's account in the same manner, then the fiduciary needs to decide what constitutes an appropriate level of risk and return for the plan and invest accordingly. Any age-based investment strategy (e.g. higher risk for younger participants and lower risk for those closer to retirement) would by design be counter to the interests of certain segments of the plan population. A particularly sophisticated fiduciary might seek to use an immunization strategy to hedge against investment losses. This is typically more applicable to a defined benefit plan where the plan has fixed liabilities that it can anticipate, but the concept could apply to a DC plan as well. However the costs of doing so may be prohibitive for a small plan.

Thanks! I thought it was too late to add the SHNE retroactively for 2020. I will check it out.

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