Leaderboard

If Relius is Windows Vista, Datair is Windows Millennium. It all depends on the features you need though. FT William has fewer features than Relius and Datair but is very streamlined and is web based. ASC has more features than FTW, but is clunky (though less so than Relius and Datair). Just my opinion of course, YMMV.

I don't know if FIS knows the answer to that question. I recently attended a conference with the architects of FRP and they weren't even sure when the DC compliance piece was going to be added to FRP. The first generation of the software will have the recordkeeping only piece.

Is there a question here?

The term-of-art here is "cutback" and the anti-cutback rule (Code §411(d)(6)) prohibits the retroactive reduction of an accrued benefit - and it applies to HCEs every bit as much as it applies to NHCEs. While the employer can decrease yet-to-be-declared discretionary contributions for 2024 and beyond, going back and changing an already deposited 2023 contribution seems like a clear-cut improper cutback to me. For my part, I would not be comfortable doing that. That is, I agree with Mr.@Bill Presson but used more words to say it.

I'd do a final for 2024 and include the 6 cents as if distributed in 2024. Most likely, the numbers wont change at all since you'll round to whole dollars anyway

I'm (attempting) to create a kind of decision tree / flowchart to easily figure out what tests need to be run on a given plan. That said, it's quite nuanced and I'm by no means an expert. I've added a picture of my progress so far. My company works exclusively with DC plans, over half of which are safe harbor. This is my first year doing testing so I very well could be mistaken about some things. Generally I've had my boss looking over things with me and helping me with what plans need what tests on a kind of case-by-case basis, but I'd love to just have a nice algorithmic way to figure it out. Any thoughts? Things I have wrong or need to add?

This is a pet peeve of mine, you can't "fail" the top heavy determination (aka top heavy test). You are just top heavy or not top heavy. In this case you're top heavy. Not a failure. The actual rule is that in a top heavy DC plan, each participant who is a non-key employee must receive an employer allocation equal to at least 3% of their compensation, or a percentage equal to the highest percentage allocated to any key employee if it is less than 3%. This allocation may impose a last day rule, meaning employees who are terminated before the end of the plan year do not need to receive the top heavy minimum. The rule was modified by SECURE 2.0 so that employees with less than 1 year of service or who have not attained age 21 do not need to receive the top heavy minimum contribution. This is effective starting for 2024 plan years. Since your plan is profit sharing only with a pro rata allocation, you shouldn't normally have any issues with the top heavy minimum, as each non-key employee would receive the same percentage of employer contributions as each key employee. However a couple of things to watch out for: If the plan excludes any compensation for allocation purposes (for example, pre-entry compensation), that definition of compensation may not be used for the top heavy minimum allocation, even if it is a 414(s) safe harbor definition. The plan must use full year (415) compensation. If the profit sharing allocation has a service condition, for example, the employee must complete 1000 hours of service in the current year to be eligible for a contribution, then an additional top heavy minimum might be needed for participants who were active on the last day but did not complete the 1000 hours. Employees who are not participants (have not met the plan's eligibility requirements) do not need to receive a contribution.