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Is there any compelling reason to remove the MP accounts prior to consolidating on a platform? They are already dealing with in-service limitations and QJSA requirements on those accounts, I would think that would become easier on a platform unless the provider cannot handle or handle differently than other portions. Note that MP in-service can be lowered to 59 1/2 now too, if that helps. If you really had to parse those out, I think you could spin-off those accounts into a new separate MP plan - essentially reverse the prior merger - and then terminate that plan. Participants would have to waive annuities with spousal consent, but you couldn't force that, and they could roll lump sums as desired into their IRAs or into the PSP.

In my work with many professional service firms, they do these kinds of non qualified deferred comp programs quite often. Usually the partner will "retire" as a partner and continue working for 2-5 years. Those plans would almost always use 3401(a) as the definition of compensation because those non qualified distributions are considered earned income in that definition. Allows the former partner to still defer into the 401(k) plan if desired.

I agree, leave it blank. To my knowledge, the responses to these new compliance questions (at least for the 2023 forms) are not edited. They could have, but apparently did not, build some edits to check the pension codes for a 401(k) feature and then checked to see if there were responses to the new compliance questions.

I agree it should be blank. If the plan is not a 401k plan, it doesn't apply.

Owner only plans aren’t subject to ERISA Title I so 8955-SSA isn’t applicable.

An actuary is a person who, after reading this quip, checked to make sure the "once every 17 years" calculation is correct.