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Michael B. Preston, who was an enrolled actuary, was a giant in the pension field. He contributed so much to the employee benefits community. He posted 6,569 messages onto these message boards since he joined in 2001 (!) -- questions, answers and comments that helped to inform and educate hundreds, perhaps thousands, of his peers. They're all still here and on the search engines, so his wisdom and humor will continue long into the future. During the 1990s, Mike was a system operator of the PIX ("Pension Information eXchange") BBS (i.e., a "bulletin board system"). PIX basically was a server running proprietary software on a particular dedicated personal computer that had a dedicated telephone number. Members would use their PC (and a modem) to connect via a long distance phone call, so that the latest discussions could be downloaded for reading and for adding comments. Later, when the World Wide Web became popular and PIX closed, Mike become an active participant and later a "moderator" on these BenefitsLink message boards. An outstanding servant and leader in his profession, Mike was awarded the Edward E. Burrows Distinguished Service Award in 2017 by the ASPPA College of Pension Actuaries, which is "presented annually to a pension actuary who has gone above and beyond in forwarding ethics, education, beneficial legislation or regulations that enhance the private pension system or the professionalism of enrolled actuaries within the private pension system." We will miss him so much!

Breakfast will always be chancy without Mike pulling my bacon out of the fire. RIP Mike 🙏

Remember to check the plan document to make sure the plan does not use the Top Paid Group election to determine the HCEs.

Yup! Thanks for your help. I know all this but don't deal with it every day. Tend to second guess myself. With time it will become second nature with experience.

It is fair to recognize that for excess deferrals that are not a 401(a)(30) violation (i.e. the excess is not known to the plan), the participant has the responsibility to report the excess and to choose how much of the excess is in each of the plans. It the participant does not provide this information, neither plan will know about the excess and each plan will not be able to account for the amount of the excess. Each plan doesn't know what the plan doesn't know. If the participant does inform a plan that it holds an excess deferral, then that plan's recordkeeper should ask for information about the amount of the excess and the type of deferral (pre-tax or Roth) that is in that plan. Then recordkeeper should properly account for the excess going forward. Note that the reg says "For this purpose, if a designated Roth account includes any excess deferrals, any distributions from the account are treated as attributable to those excess deferrals until the total amount distributed from the designated Roth account equals the total of such deferrals and attributable income." If there is no separate accounting, then the first dollars out are a refund of the excess plus earnings and are not eligible for rollover. (This is similar to what is done for RMDs.) As evidence that @Lou S.'s odds on how this is reported are fairly accurate, I observe that I have never seen a conversion data request that asks for the amount of excess deferrals that are in a participant's account.

RMD first, then rollover. Must have typed too fast.

Rollover first? Or RMD first? Because the RMD has to come out if the participant will reach RMD age during the Distribution Calendar Year.

Just make sure the earnings for the HCEs are prior year since that's how the status is determined.

In this morning’s psalms and canticles, I’ll include prayers for Mike Preston and his family.

I didn't know Mike, but always respected and benefited from his knowledge and opinions. The Enrolled Actuary at my former place of employment was a PIX member, and Mike's opinions came up in discussion frequently. He'll be missed.

So sorry to hear about Mike. I (Jim Norman) was fortunate enough to be a PIX sysop along with Mike. I learned a lot from him, he was incredibly generous with his knowledge. I also really enjoyed the occasions when we got together. He was one of the good guys. RIP Mike.

Thanks. Yes, Nationwide is a mess. I called lot of places, finally one place (Nationwide Branch Office in Chicago) help me out and I got the check yesterday.