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There is no duty of consistency.

Lori, at the risk of repeating some of what was already said .... Yes, your mother's birthdate was likely an input in converting the monthly amount that could have been paid for your father's lifetime only into the (smaller) amount payable as long as either he or your mother remains alive (the 100% J&S option) . In most plans, this conversion reflects the exact ages of retiree and beneficiary at the time payments begin, so that in these typical plans using an incorrect birthdate for your mother would make the result incorrect. As David Rigby says, in some plans exact ages are not always used so that having an incorrect beneficiary birthdate needn't impact the result -- but even these plans often refine the standard adjustment where there is a large enough difference in age between retiree and beneficiary (such as with an apparent 15 year difference in this case) so that the incorrect date could have made an impact even if the plan here was one of these. Assuming that the pension plan here is one in which your mother's (apparent) age factored into the calculation of the 100% J&S benefit -- as is very likely in my experience -- then the impact would have been to make the J&S benefit lower than it should have been. The plan thought that your mother was 10 years younger than she really was, and so expected more future survivor payments to her than if her correct age had been used, leading to a steeper reduction in converting to J&S than if that correct age had been used. In other words, getting this error corrected seems like something you would want to pursue.

C.B got it mostly correct. There is a possibility, which might not be common, that the "adjustment factors" (as specified in the plan) do not directly reflect the actual ages of participant and/or spouse. I've seen a few plans that define those factors much simpler; for example, the 50% Joint-and-Survivor factor defined as 95%, the 75% Joint-and-Survivor factor defined as 90%, and the 100% Joint-and-Survivor factor defined as 85%. However, if the factors do reflect actual ages, I estimate the difference between using YOB38 vs. YOB48 to be about 3-4%.

Short answer, yes, it almost certainly would affect it. Longer answer: As a participant in a defined benefit plan, your father would have earned something called an "accrued benefit." This is usually based on his salary and the number of years he worked for the company, and it is usually expressed as a number of dollars payable monthly starting at his normal retirement age and ending at death. Let's say that his accrued benefit was $2,000 per month. You said he started receiving benefits 30 years ago, so 1991, and his date of birth was 1933 so he was 58. If the plan's normal retirement age was 62, there would have been an adjustment for early retirement; so instead of $2,000 per month starting at age 62, his benefit would be maybe $1,800 per month starting at age 58, depending on the plan's early retirement factors. If the plan says that the $1,800 per month was payable starting at age 58 and ending at his death, then there would need to be another adjustment due to the fact that the payment ends at the later of his death or his spouse's death. The plan's actuary will calculate the amount of the adjustment, but the younger the individuals involved are, the larger the adjustment (and the smaller the payment) will be, since it would be expected to be paid out over a longer period of time. So, if they have been paying out all these years based on an adjustment for a 58-year-old and a 43-year-old, it would be potentially very different than the adjustment for a 58-year-old and a 53-year-old. In order to determine if they did it correctly, you would need to know, at a minimum: Your father's accrued benefit at the time he retired The plan's early retirement adjustment from normal retirement age to your father's actual retirement age The plan's adjustment factors for the form of benefit elected by your father at at your father's actual retirement age using your parents' actual ages Using those, you should be able to calculate the amount of the monthly benefit that was actually payable. If the plan provided cost of living increases or other adjustments for retirees, then there may be additional factors that need to be taken into account. Good luck!

I'm not arguing with you about the correctness of any of this but I can try to tell a new client why a giant like ADP is wrong, or I can poke myself in the eye with a sharp stick and get to the same place.

All remarks here are off the top of my head with no further research, so take it with a healthy dose of skepticism... First, I believe the "less than 10 years younger" is referring to calculation of Required Minimum Distributions, not the calculation of a J & S payment of a defined benefit. Yes, I believe it is possible that it could affect the amount of payments. Now, it is possible that the amount was correctly calculated, and the payment is actually correct, but they just have a wrong DOB in their records somehow. But it it is also possible that the amount was incorrectly calculated based on the incorrect DOB, and that your father was overpaid for 30 years. The plan may attempt to recoup overpaid amounts by reducing future payments, for example. I'll defer to some of the DB experts (I am NOT one) and attorneys to flesh this out more with additional details and more informed opinions.

There are many TPAs in the Valley who can help you. You can hire one of those TPAs, they will take over the plan, and then you can roll over the TD Ameritrade assets into it. I can help you if you don't find anyone else; I'm in LA.

I find the question a bit confusing so I'll start with your last comment Austin. If you cherry pick the people in each component plan, the classifications are not reasonable, so each component plan must pass the ratio percentage test. Yes that is definitely true. Once you pass that hurdle, you test as if you have two separate plans, and if each rate group in each component does not pass 70% ratio percentage, you must proceed to the average benefits test just like you were testing any two separate plans that fail ratio/percentage but pass the NCT. Does his help?

Please re-read my comment. You have a problem that needs fixing.

Well, we prove ADP wrong often. It's the approach you take in conveying the information. We discuss it, but then produce regs, secondary source write-ups, our write-ups, and let them talk to the experts (me and my team!) who have a knack at being persuasive!

I almost mentioned this in my earlier reply. I'm going on the assumption that the doctor asked ratherbereading to run a projected ADP test in late 2020 to see what was the maximum he could defer without failing the ADP test. Because we all know that an owner with earned income has to make their deferral election before the end of the year, even though they have until their taxes are finalized to make the deposit, right?

What ESOP guy said. Everything should be done under the plan name and id number; the brokerage firm writing the check(s) is irrelevant info.

Yes, it makes sense. When you reclassify deferrals as catch-up due to the ADP test, the only amount that gets reclassified is the amount that would otherwise be refunded. So it makes sense that the amount reclassified for the one HCE is equal to the amount of the refund for the other HCE, earnings aside.

The accountant is technically correct. However it wouldn't surprise me if the IRS would approve a retroactive amendment of some sort which applies the deduction to 2019. Through EPCRS, of course.

I believe you would just need to file an amended 5330. There is a section in the instructions for "Claim for Refund or Credit/Amended Return."

I would use the EIN that was used to deposit the withholding. It is my understanding the IRS computers will try to reconcile the deposits they got to the amounts listed as withheld on the 1099-Rs. To not have the 945, 1099-R and 1096 not all sync I think could cause letters from the IRS about their inability to reconcile the amounts later in the year. I will warn you I am not an expert on the topic but that has been my understanding for years. Anyone want to confirm or deny what I said would be great. I would think that is the broker's EIN but if they made the trust deposit the withholding with its EIN I would give serious thought to using that EIN.

There is no flexibility on SEP-IRA contributions; you can't waive your own share.

@Bird I think you meant to type this.