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402g limit is calendar year. So no issues. 2020: 18,000. less than 19,500. all good 2021: 16,500. less than 19,500. all good The participant will need to keep an eye out for 402g limit if deferring into another plan. Shouldn't be an issue with you as long as new employer is not related to old employer.

Elective deferrals under a § 457(b) plan with a matching contribution under a § 401(a) plan is a common design (if the governmental employer has sufficient authority under State law). I have never seen it done as money-purchase plan. Governmental Plans Answer Book suggests (at Q 6:26) that stating a plan as a money-purchase plan might impose a tax-law funding requirement to the extent needed for the plan’s benefit to be sufficiently determinable under 26 C.F.R. § 1.401-1(b). But a governmental plan stated as a profit-sharing plan (with no § 401(k) arrangement) has no Internal Revenue Code funding requirement. I’m unaware of a good reason for a governmental employer to self-impose any more funding requirement than State law commands. Under Internal Revenue Code § 401(m)(4)(A)(ii), a matching contribution includes one made to any defined-contribution plan on account of an elective deferral, which under IRC § 401(m)(4)(B) “means any employer contribution described in section 402(g)(3).”

Consider these interpretive rules: “[T]he plan administrator of an employee benefit plan subject to the provisions of part 1 [of subtitle B] of title I shall furnish a copy of the summary plan description . . . to each participant covered under the plan (as defined in § 2510.3-3(d))[.]” 29 C.F.R. § 2520.104b-2(a) https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XXV/subchapter-C/part-2520/section-2520.104b-2 “An individual becomes a participant covered under an employee pension plan” no later than “[t]he date designated by the plan as the date on which the individual has satisfied the plan’s age and service requirements for participation[.]” 29 C.F.R. § 2510.3-3(d)(1)(ii)(A)(2) https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XXV/subchapter-B/part-2510/section-2510.3-3#p-2510.3-3(d) If a statute is ambiguous, a court defers to the agency’s notice-and-comment rule if the rule’s interpretation is permissible. Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (June 25, 1984).

If your firm is owed an amount for work you completed, consider whether you want to submit your claim. Not submitting a claim promptly might time-bar it. If the employer/sponsor is or was a business organization, there might be persons beyond the decedent with some authority to act for the business organization. And the decedent’s executor, administrator, or other personal representative might have some authority to administer or wind up the business. Further, consider whether you do or don’t want to be available if a personal representative wants to engage you to prepare the outstanding information returns.

As far as PBGC is concerned it's a reversion of excess assets to the plan sponsor. The transfer to the QRP to avoid taxation/excise tax is an IRS concern and not relevant to the 501.

If you are thinking of a 401(k) Plan with elective deferrals only where they choose to defer 0%, they are still participants, they just have a $0.00 balance. They still need to get a SPD.

That isnt the issue. The new penalties apply to returns required to be filed after 12/31/19, yours were not. The penalty amount is a programming error, they had the same issue early 2020 and fixed it, but the fix somehow got rolled back (I confirmed this with IRS last year.) As for asking for the same form again, it is probably a mail issue. The mail sorting and processing at the IRS is still facing backlogs. I had some stuff mailed in October 2020 that still had not made it to the right place by July 2021. In July, I was told to expect longer delays for a while when you send them papercopies.