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I am pretty sure clients keep nothing we send them. It's very annoying.

Typically we'll forward an email where the documents were already provided and ask if they need any help with something.

Put the additional match in a bank account in the plan's name (under the trust id #). When the plan comes out of blackout, put the funds in participant accounts and adjust for earnings. Check the 415 rules for when the contribution will be considered an annual addition for the participant. I'm not sure if it would be 2020 (when the funds left the ER and put into the adjunct trust, or bank, account) or 2021 when they actually gets invested in the accounts. Really only relevant if anyone is close to maxing their 415.

I wanna work where you work. 50 plans is 4 a month, one a week. I could handle that!

Participants will need to be provided at least 30 days in advance with an updated fee disclosure that explains the fees which may be charged against their account.

We post the plan documents on the website for the plan sponsor/financial adivisor and the SPD for the participants/sponsor/advisor. We also post the last three 5500 forms and the annual plan testing for the sponsor/advisor and the SAR for all parties to the website. We then direct them to the web to find the data.

In the past I have put provisions in the spinoff documents themselves (e.g., board resolutions and/or plan documents) that state that the existing enrollment and beneficiary designation forms will be assumed by the spun off plan until new are obtained. Never had a problem with that. Needs to be communicated to the participants of course.

Most, but certainly not all, clients will want to also obey IRS positions instead of intentionally operating a plan contrary to IRS guidance. You have summarized Code Section 411(a) and its regulations accurately. I do not claim that the vesting schedule change would violate Code Section 411(a). The link I provided uses a different rationale for explaining its conclusion. In the example, a participant who has 1 year of service and is 0% vested on a 2-6 year (20% per year) graded vesting schedule is an a plan that is generally switching to a 3-year cliff vesting schedule. The IRS concludes that the participant must have a vested percentage of 20% after earning his/her second year of vesting service. Obviously it's fine if you or BG5150 disagree, but I certainly wanted to alert readers of this thread of the IRS' more restrictive position.

In the context of the original question, if your rounding method gets you to 1 or more, then at least theoretically ok. However, there are potential document and timing issues with the timing of the "election" and whether you can simply "elect" it or must amend plan, possible anti-cutback provisions (although I would say that's generally unlikely) - facts and circumstances issues to be determined for each plan.

I think the goal nowadays is 3X. This is also why NEED support staff. The biggest eye-opener for me once I had to use detailed time-tracking was how incredibly wasteful it is to have highly competent personnel perform clerical tasks, which is often the case in smaller firms where each employee does it all for their client list.

This is an interesting thread. It's not really about how many plans, for the reasons mentioned - size and complexity. A different metric, not necessarily the be-all and end-all, is revenue. I think most owners feel their admins should be billing at least 2 times their salary plus benefits; some maybe 3X. I'm a lousy businessperson/owner and never really got to 2X. 300 plans with one person primarily responsible sounds pretty crazy to me. I imagine they would be totally and completely screwed if you left...

We generally say something to the effect of, "Sure, we'll be happy to forward those. Would you please tell me why you need them?" Honestly, these days when it is as simple as attaching a PDF to an e-mail, we don't find it much of a burden. Maybe we are just lucky that we don't get too many of these requests. Wasn't as easy in the old days - then these were a thorn in the side.

Sure. They could have the partnership adopt a plan and then have the member orgs as additional adopting employers.

You do not have to include them for the gateway test. You do have to include them for the rate group test.

While I recognize that 1.414(q)-1T, A-3(b) allows any "reasonable" method, IMHO you are playing with fire by taking your interpretation. Good luck convincing an auditor that this is permissible. It isn't reasonable to abuse this discretion to blatantly ignore common sense coverage and nondiscrimination testing rules. I'd strongly recommend that you reconsider this. Good luck!

The ASG is treated as a single employer for purposes of 401(a)(26). Since plans may not be aggregated for 401(a)(26), any plan put into place would have to cover at least 40% of the ASG members (or if there are only 2 members, both members).

Read IRC 411(a)(10). https://www.law.cornell.edu/uscode/text/26/411 The most common method of doing this is probably to apply the new schedule only to those who become participants after the effective date.

Seems to me you need to find out the REASON those 2 NHCEs are leaving. The crux of determining a partial plan termination is whether the terminations are employer-initiated. Based on the math you've provided, if these 2 NHCEs were fired, you have a PPT on your hands. In that case, the hours they've worked are not a factor as they become 100% vested regardless. All PPT determinations are facts & circumstances, so it may be advisable to get a legal opinion.