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unless the life insurance policy is owned by one of the entities in the "FROM" column the answer is likely no. https://www.irs.gov/pub/irs-tege/rollover_chart.pdf You own the policy yourself? directly? I don't see why it would be a rollover, its not coming from a tax qualified retirement account. I realize the life insurance feels like a tax qualified account - but it is a very specific kind - upon death. Its not the same as tax deferred or tax qualified retirement account. which is what it needs to be coming from in order to be eligible for rollover into a 401(k) plan.

We typically don't see this if the plan has been terminated for a while. Usually when amounts do appear well after the termination and final reporting of the plan, the amounts are attributable to a settlement of litigation. It would be absurd to resurrect the plan, update for recent legislation, pass around some pennies, make payments, amend the prior final 5500, prepare a few more 5500s for the intervening years and file another final 5500, send SAR to participants, ... Let's get real and not overthink it. The trustees or plan sponsor should ask the brokerage firm to close the account and write off the amount. If the brokerage firm adamantly refuses, then one of the former service providers likely will be willing to send an invoice to the brokerage firm to close out the account.

It seems Notice 2024-73 is introducing some new terminology in an effort to deal with the long-standing ability of 403(b) to exclude students from deferring and having that exclusion not violate the universal availability requirement. The position in the Notice seems to accept an interpretation that there are two components to the exclusion - one being a student (based on status and not service) and the other being an ERISA LTPT employee (based principally on service), and that being a student permits the exclusion to stand. Question 6 adds that becoming a "former ERISA LTPT employee" cannot be excluded under section 403(b)(12)(D) to exclude the individual from getting a match or NEC. The new terminology in the Notice references "ERISA LTPT employees" and "401(k) LTPT employees" in Section VII with the request for comments: Additionally, comments are requested on any rules with respect to section 401(k) LTPT employees (including former section 401(k) LTPT employees) that should apply differently for ERISA LTPT employees under section 403(b) plans. This interpretation of this Notice conceivably could open the door for using "intern" as a classification based on status, but the Notice comments that more is coming about plans other than 403(b)'s. I want to see what gets issued in a notice about 401(k)s. This whole issue seems to be adding layers of complexity and increased data collection that are going to make plan administration significantly more complicated.

I think the 2/3/25 date would still apply to Form 5500. Note that the release provides that "This means, for example, that the Feb. 3, 2025, deadline will now apply to:"... so the examples they provide (which do not mention Form 5500) are merely illustrative and not exhaustive. Like you said, all the other IRS releases include specific mentions to Rev. Proc. 2018-58 and include an "affected taxpayers" section (e.g., like in this one issued just 3 days prior: https://www.irs.gov/newsroom/irs-announces-tax-relief-for-taxpayers-impacted-by-severe-storms-and-flooding-in-new-york-various-deadlines-postponed-to-feb-3-2025). Notice that both IRs provide lead-in sentences about "applicability" to the effect that "These taxpayers now have until Feb. 3, 2025, to file various federal individual and business tax returns and make tax payments." The statements are IDENTICAL. If Form 5500s are covered under the NY announcement, then I think it's reasonable to think they also apply to the LA announcement.

If these are governmental plans, which coverage or nondiscrimination rule worries you?

If it's not an annual addition because of their 415 limit being zero, I'd argue those aren't actual deferrals triggering the THM. (As opposed to an ADP refund)