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Well, I am an actuary, and I'm also grateful for the question. Discussion above about communication is the central issue and answer. This works both ways; when there is turnover, the best action is to proactively introduce the new staff member (such as assistant, banker, investment advisor, auditor, attorney, analyst, actuary) to all the other teams who have an interest in the project/client. In addition, make sure there is clear understanding of who needs what information, who provides the information, and when it is needed. There are many examples of other professionals who have a specific responsibility, but the actuary has the expertise to help, even without credit. Example 1, in the case of a DB plan sponsor with GAAP financial reporting, there is a need to develop a market-based discount rate; the actuary will have significant ability to help with this (probably having done so many times), even though not the final decision. This will be of use to both plan sponsor and auditor. Example 2, the attorney may draft a new plan document or various documents related to merger or acquisition; the actuary will appreciate being asked to review any such documents in advance; if related to M&A, the actuary will opine on all types of employee benefit plans but also contributing w/r/t administrative procedures outside the attorney's knowledge base. Example 3, when a company-to-be-acquired has nonvested or partially vested participants in one or more qualified plans, the actuary can provide help with evaluating the cost of awarding 100% vesting immediately prior to the transaction, information that could be useful to both the company and any other negotiators. Example 4, the actuary knows to ask about other possible plans when there is a Top-Heavy concern or a 415-limit concern; I've seen many prior cases where a DC plan vendor was not aware of the DB plan existence, and when so informed, that DC vendor did not understand the concept of "required aggregation group".

If I were an actuary, I would be tempted to respond to the question with, “Some of us are beyond help, but thanks for asking.”

Integrate into data collection process, anticipate and respect their professional needs and deadlines, engage them into post-cycle planning process. To sum it up - COMMUNICATE.

@RatherBeGolfing raises some of the operational issues that the client must understand fully and be able to set the expectations of participants on how the SDBAs will work inside the plan. Ascensus and Schwab each have a lot of experience with SDBAs inside plans and they also have links to share data electronically. While that sounds wonderful, there remain complications for recordkeeping the plan. One of the bigger challenges stems from allowing multiple contribution sources to be invested in the SDBAs. There is potential for a contribution source to be pre-tax or Roth. Each source may have differing in-service withdrawal provisions, differing vesting, differing loan availability and other variances in features. When recordkeeping a plan that uses a menu of mutual funds, each transaction be it a contribution, distribution, exchange, dividend, new loan, loan repayment... can be labeled with a plan account (deferral, NEC, match, rollover, ...) and the mutual fund in which the transaction occurs. When there is what @RatherBeGolfing termed "shadow posting", the recordkeeping treats the SDBA as if it is a single investment. The identity of the mutual fund is lost. When recordkeeping with a menu of mutual funds, the price per share of each fund is known after market close and before market open. Depending upon the frequency in which the market value of the SDBA is sent to the recordkeeping system, the "price" of the SDBA investment may not be known within the menu of mutual fund's time frame. The plan should not allow participants to grant trading privileges to brokers or financial advisers that are not approved by the Plan Sponsor. Allowing participants to choose advisers of their choice is a recipe for chaos, and could lead to questions over who is controlling the investment of plan assets. The plan audit should not be dramatically impacted by the SDBAs. Schwab and the trustee both should be issuing reports that include all of the detail needed by an auditor with experience auditing SDBAs. The Plan Sponsor should vet the auditor to confirm that the auditor does have this experience of the cost of the audit could skyrocket. I share @RatherBeGolfing's concern about who is providing compliance services although my concern is driven more by the competence of who is providing the services rather than by having SDBAs as an investment option. Note that the proposed arrangement for the SDBAs is relatively simple compared to some of the plans I have recordkept. For example, this arrangement: uses only one brokerage firm and participants do not get to open an account at the brokerage of their choice' restricts investments to mutual funds and participants cannot invest in stocks, bonds, CDs, ETFs, ETNs, gold, annuities...; does not allow trading in options; does not allow investing in assets that do not have a readily determinable value such as real estate, LPs, private placements, art... The advice to the client is to know the details, prepare written policy (including dos and don'ts), and communicate clearly to participants. Some plans go so far as to have a participant sign a representation that the participant understands the policy.

I suppose unless there's a mandatory payout limit in the plan, there's no reason they can't stay await direction from the participant/beneficiary.

For solo plan I don't fiduciary issue is concern and would park in cash/money market. Even if plan was participant directed and had fiduciary concerns, I think investing the suspense in a non-volatile fund would be prudent - IMHO.

Peter, Who does the testing for the plan? The PS? That is both good and bad. Its good because the availability and use will clearly be nondiscriminatory, but considering the number of accounts the admin of the plan will be more complicated. Are they actually able to restrict the investments in the SDBA? Unless the SDBAs are integrated with the RK platform, it may be difficult to restrict. Remember, they also have to monitor these accounts, and that may be difficult as well. Sounds like they are "shadow posting", in other words, you will be able to see the balance of the SDBA in Ascensus, but probably not the activity. If so, consider the added complications of tracking fees, g/l, dividends, etc. Also, you may want to consider the EBSAs not so favorable view of brokerage windows in general, and whether this approach will allow the plan fiduciaries to meet their obligations (fee disclosures, monitoring investments, etc). It worries me that there is no TPA (unless they have someone in-house that can perform testing, prepare required disclosures, reporting, etc). If they are simply shadow posting balances to Ascensus, reconciliation will be a headache.

What they can or cannot do and how much can be allocated to each member depends upon how the LLC is taxed. Is the LLC taxed as a partnership, S-corp, or C-corp? Since you mention guaranteed payments and did not mention W-2s, I would guess taxation as a partnership. On the other hand, distinguishing between compensation and profits suggests that taxation as a corporation is a possibility. Guessing and not knowing could be the reason there have been different answers.

Many charities and other tax-exempt organizations have an accounting year meant to measure a program year, and a year ended June 30 is a common choice. Some profit-seeking businesses have seasonal or business-cycle reasons to use an accounting year with an end other than December. In my experience, it’s often simpler to administer an individual-account (defined-contribution) retirement plan with a calendar plan year, rather than a plan sponsor’s or participating employer’s accounting year. But much depends on the plan’s provisions. And on how strong or weak is the employer’s need or interest in measuring an accrual for a nonelective or matching contribution on the employer’s accounting year. If there’s a reason to revisit a selection of either the employer’s accounting year or the plan’s accounting year or other plan year, consider involving both sets of decision-makers, including each’s lawyers and accountants.

Correct. All plans maintained by the employer or by a predecessor employer are treated as a single plan for purposes of applying the 415 limit. 1.415(f)-1(a)(1)