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Our firm uses ftwilliam and as far as I know it can’t do restructured testing (breaking the plan into component plans and testing separately). I was wondering how other people were doing this testing? Do other software programs do it? Do you have to do the testing outside of a software program like in excel?

Is it possible that the plan sponsor was entitled to the extended filing date of Feb 15, 2022 due to Hurricane Ida?

Looks like that thread was deleted by the individual who first posted the question. It's a good topic -- feel free to start a new thread. (Only the original author and the moderators can delete a thread, so as long as it stays relatively on-topic, you have control if you start the discussion.)

Otherwise, can we all acknowledge that Keogh's sunset in 1984 (TEFRA '82), were laid to rest in 2000 (IRS Publication 560), and officially expired in 2002 (EGTRRA '01)? This is in some ways worse than the "Solo-401(k)" naming convention.

The IRS will have deactivated the TIN it issued in 2006. But that's not the problem here; the problem is that the two financial institutions have two different numbers and can't ACAT the assets. I'd probably go with the one that the financial institution has from 2006, and worry about re-activating it later. Deactivated doesn't mean it doesn't exist or has been assigned somewhere else, although I suppose eventually they recycle numbers. See link below to reactivate. https://www.irs.gov/retirement-plans/how-to-obtain-or-re-establish-an-ein-for-a-retirement-plan-trust

Amend the filing to reflect DFVCP?

No problem at all from my viewpoint. Many documents (Relius, for example) you would just specify the effective dates of those changes in the Appendix. So you restate 1/1/2022, with one or more provisions in the restated document not taking effective until 8/1/2022, as noted in the Appendix.

Did you not contact FTW about it?

Bill - thanks for the confirmation. Not a safe harbor plan. The professional is moved from one professional firm to another earlier this year. No provisions changing, just want to reference the new ASG.

It's probably the only thing I'll defend ASC's admin software on, but they let you assign employees to components and test that way. I had a DC plan where an owner's kid was younger than everyone but they at least wanted him to get the same 5% gateway floor the NHCEs got, while the owners were up at like 20%. So Component 1 was on allocations, Component 2 was on a benefits basis.

If CG then you must aggregate for $250k threshold. Is this a CG because CA is a CP state, or because they have minor children, some other reason? One or more of the current pension bills being considered (SECURE 2.0, RISE and SHINE, EARN) has provision for making these situations not CGs w/o needing to worry about community property or minor children, but whether that makes the final cut and gets enacted, we'll see.

I guess we can forgive you for being a relative newbie - but the DOL's insistence on a VFCP filing - as known by for those with more experience - goes back a good decade or more. If that was meant as a political statement, then you clearly are in the wrong place....

Actually it's neither not necessary nor condescending. It is necessary when you see the number of people out there not masked or social distancing in large crowds. It's evidence of concern for another. I always close my discussions with my team thanking them for all they due, and reminding them to be safe. I *care* about them. They are in Indy, and if you peruse the news, you'll see hat IU Health is in crisis mode with hospitalizations in excess of even the prior peak. Pretty good evidence that the message hasn't reached all.

Go Brandon!