Leaderboard

1. If plan was frozen in 2017, you would use the 2017 limit of $215,000. 2. If the freeze amendment specifically allowed the future $415 limit increases, you will use the current $415 limit. 3. Based on the plan document definition of years of benefit service and years of participation, owner may have 4 years of participation for $415 proration purposes. If none of this helps much, just unfreeze the plan.

Thoughts? "After considering the public comments, the Agencies decided to adopt the proposed counting method change for defined contribution individual account plans by adding a new line item on both the Form 5500 and Form 5500-SF for defined contribution pension plans to report participants with account balances at the beginning of the plan year (there already is a line item for reporting the number of participants with account balances at the end of the plan year). Instead of using all those eligible to participate, defined contribution plan filers will look at the number of participants/beneficiaries with account balances as of the beginning of the plan year (the first plan year would use an end- of- year measure) when determining if they are eligible for small plan reporting options, e.g., the Form 5500-SF. Conforming changes are also made to the short plan year filings and the “80-120” Participant Rule instructions to reflect this new counting method. See Appendix C for details on changes to forms and instructions related to this audit related participant counting method change." https://www.dol.gov/newsroom/releases/ebsa/ebsa20230223 https://public-inspection.federalregister.gov/2023-02653.pdf https://public-inspection.federalregister.gov/2023-02652.pdf

Agreed, thanks Bird. I think I just needed to vent about it in my frustration 😁

Thoughts? It's about time? Good change. I've had a plan for years on the edge of 120 that has like 35 people actually participating so nice to see they won't be pushing into audit territory anytime soon with this change. I was a bit worried since I think they have just enough long time part times who might push them over 120 but the chances that those will actually participate is quite small.

In past years, Form 5500-SF could be used for an owner-only situation if the return was going to be submitted electronically. That is no longer the case. Now a Form 5500-EZ is required.

A "plan" must pass both coverage AND nondiscrimination. A "plan" each of your mandatorily disaggregated components and any permissively disaggregated components. You cannot choose to test "plans" A and B together for coverage but separately for nondiscrimination, whether nondiscrimination is ADP, ACP or general 401(a)(4).

We had this happen, file an anended to include SB, no problem yet. I think once you file completely, you're OK.