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NO! See Q 33a EFAST2 FAQ

So now you're arguing with us? Wow. Just an FYI, "Voluntary after tax contributions" are not exactly common and not listed on the IRS chart.

There is no passion like that of a functionary for his function. BTW, no one really thinks the IRS should be called "the Service".

Maybe the IRS's AI is too much A and not enough I.

https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/faqs/efast2-credentials#q17

Ok, so after 40+ years in the TPA world I retired at the end of 2021. In 2022 I terminated my small solo-k which I sponsored as a sole prop for some side income, plan was alway under $250k. I rolled it to an IRA and in January 2023 I filed a 2022 EZ marked as both the first, and the final return. Today I get a letter 1072C from the IRS telling me that my EIN is XX-XXXXXXX and that I should always use this number in filing the EZ. Well, duh! Yes, I know that’s my EIN, that’s why I put it on the EZ form in the first place. I checked my copy, the number on the EZ is correct and matches the number IRS states in the letter as well as on the original EIN assignment letter I received years ago. The letter doesn’t say I have to do anything, and it acknowledges receipt of the 2022 EZ filing. So Whiskey Tango Foxtrot? I don’t recall any of my clients over the years getting a letter from the Service like this. anyway, just thought I’d put this out there in case some of you start getting client calls about such a letter. I think IRS has a special department to create correspondence designed to waste TPAs’ time. Definitely helps remind me why I was ready to retire (and enjoying it immensely, especially most days where there’s no IRS envelope in my mailbox!)

The LTPT rules only apply to a plan with a 401(k) feature in 2024, and to a 401(k) or 403(b) starting in 2025.

Just as an update, and maybe a laugh. Anyway, we did documents for the termination of the Plan, using proper dates, etc... Would you believe the attorney revised the dates in materials to use the retroactive date that he was recommending. Luckily, it is well documented that we used proper time frames and such, so we easily put the kebosh on that! Client understands the "reality of the situation" so termination is being done properly as we processed. For "venting", doesn't it just roast your butt when some "outside expert" comes in and acts like they know it all, and then they actually modify the work that you did to reflect their error, and then send to the Client as if we made the changes? As I said earlier, I don't claim to know everything, but one thing I would never do is modify someone else's work WITHOUT DISCUSSION OR EVEN NOTIFICATION, and then try to pass it off as the work of that other person. We wouldn't have even known if the Client didn't send us a copy of what the attorney changed and sent to the Client asking us if this was correct! We, of course, were not even copied on that mailing. It just went to the Client under a short cover letter that said "use this version". I don't know, but that seems that someone has a bit too much chutzpah, and at best, is not someone we should ever work with again since they change our work and send to the client as if we agree with the change! I can only say I would never do something like that. Isn't that illegal?

This thread truly is an example of a Donald Rumsfeld "unknown unknown" for the OP. “There are known knowns — there are things we know we know. We also know there are known unknowns — that is to say, we know there are some things we do not know. But there are also unknown unknowns, the ones we don’t know we don’t know.” We all know how that turned out.

If you are not yet the TPA then I don't think that Precept 10 would apply in this case. I'm not going to just provide information to another actuary because they ask for it unless either 1) they have a signed service with the other actuary, or 2) the client asks me to share the information directly (in which case I would simply send it to the client and they can share as they see fit).

Then why are you asking here?

Assuming the plan doesn't currently allow for discretionary match I would assume they would need to adopt the amendment before they started depositing the matching contributions to the plan but not later than the end of the plan year for the discretionary amendment. That said, if they did start depositing the match early, I think the eventual amendment would most likely work as a self correction under the newly expanded IRS rules.