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I do generally omit my "Galactic Institute Aeronautical Nuclear Titan" and "Elected Galactic Overlord" (GIANT, EGO) designations. I'm saving them for when I go into politics.

I feel mine are justified. It's only pretentious if someone with more than me lists them. 😁

They are called pre-approved plans now rather than prototype or VS

I don't think they ever said not to include fmv on the 5500. There is some confusing (to me) language in the instructions about "insurance contracts" that I finally figured out meant insurance or annuity contracts where the insurer is providing/guaranteeing the benefits. So if, say, you bought an immediate annuity paying monthly benefits, that is no longer an asset. Not including "regular" insurance values is illogical - how do you get it "out" of the assets, as an expense? And what if it is surrendered, how does it come back "in" - as a gain? (I've never done a 412(i) plan and never hope to and have no idea if that reporting is different.) Yet I've seen very experienced administrators showing premiums as expenses and not including values.

Excellent points as always, I should have included that using the payroll version of comp vs the plan doc definition of comp is more beneficial to all employees. There would be no additional contributions or corrrective withdrawals. If they go with plan doc def some money would have to be pulled from the match.

Hi Bill Thank you for your input, yes I am trying to follow with them and see what took place. Of course, they are all hiding from me. Hope all is well.

I haven't had any occasion to do so, but probably would under the right circumstances. Even if you agree the 20% presumption is an appropriate starting point, the very small participant count should, I think, at least make the presumption easier to rebut absent some other bad factors.

Agree with ESOP guy--I've been working with TPAs since the mid-70s---(started when I was 12)---and that is a recipe for VCP as was ably noted.

The statute and Notice 2020-50 suggest that recontributions should be permitted to the extent the same participant would otherwise be eligible to make an inbound rollover into the plan. I think you can apply the same rule here, i.e., if this participant wanted to roll in a balance from a previous employer's 401(k) plan at this point, would you let them?

How does a government "acquire" a not-for-profit entity? Such entities have no owners, so you can't purchase one. Did the government buy the assets, or what happened? The other issue to consider is whether the nonprofit is now itself a governmental instrumentality. If the only member of the nonprofit is a governmental entity, there is a good chance that it is. In any event, if the nonprofit has somehow failed to become a governmental instrumentality, and is still an ERISA plan and subject to coverage rules, I'm not sure how you could possibly apply them on a controlled group basis, given that such rules do not apply to governmental plans. You would, of course, still have to apply the universal availability rules.