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The change is how you count participants for the audit threshold. You now count participants with a balance. Eligible participants without a balance are still participants, you just get to exclude them for purposes of determining whether the plan needs an audit.

2023 Form 5500 Lines 5a and 5b should report all ELIGIBLE PARTICIPANTS, even without a balance. Participants with a balance at BOY and EOY are reported on lines 5c(1) and 5c(2). So if you had 50 eligible participants at EOY 2022, you report 50 participants at BOY 2023 in 5a (unless you have a new entry at BOY). 5c on the 2022 Form 5500 had participants with a balance at EOY, that is your number to use for 5c(1) on the 2023 Form 5500.

A nice summary, Peter. The important practical point is that it should be a very conscious decision about which fiduciary is responsible for investments. Then, work through the plan terms to make sure that that fiduciary is is named by following the correct procedures for identifying the various fiduciaries and their roles. The worst thing that can happen is that someone becomes a fiduciary without knowing that they bear that responsibility, by default, by mistake, or by ignorance. One hopes that plan terms, or trust terms, provide express authority with respect to appointment of fiduciaries. Sometimes the authority to appoint is implicit. A recent question in the message boards about use of custom documents is relevant here. Custom documents, drafted with regard for fiduciary and other ERISA concerns, rather than simply tax compliance, will probably have more understandable and accommodating provisions with respect to management of investments and other fiduciary duties. The IRS is not looking out for those aspects that apply to plan operation and liabilities. Also remember that most of the time a fiduciary that appoints another fiduciary for a specified purpose, such as identifying and managing investments, still has some responsibility to monitor the activities of that fiduciary.

There is a difference between fulfilling the plan's eligibility requirements and the plan's entry date. The plan should specify all the rules needed to determine when the individual starts participating in the plan. If the plan says the entry date is immediate upon fulfillment of the eligibility requirements, then there is an argument that this participant became a participant on 12/31/2023. If the plan definition of compensation is compensation earned while a participant, then the participant will have 1 day of compensation. Best practice would be to clarify in the plan document the definition of the Entry Date.

It all depends on the demographics. That is why we test for coverage. Any time I see this type of convoluted eligibility provisions, I suspect it is a form of cherry-picking individuals the client wishes to benefit and excluding "undeserving" individuals the client wishes to exclude. This type of provision inevitably fails spectacularly when the demographics change, particularly when a change occurs mid-year and an "undeserving" individual becomes eligible for a benefit.

if you read down this thread I think some of the comments will be helpful. It will come down to how the testing is aggregated and what methods are used to pass.

Congrats on the scholarship, but more so on the decision to further your professional education. Wish more practitioners took that approach and more bosses supported such, evidenced by some of the questions we see on this forum. Even if you do not get that support, attaining a designation (and having a bit of experience) will only serve to improve your personal marketability and, with modern technology and the proliferation of remote work, enable to find the right place to practice and continue to learn and develop with organizational support. I can't opine on either organization's designations but over the years have found ASPPA and it's related entities to be a great resource. I have had less exposure to NIPA. Good luck with your continuing education and your career!

@Mleech Also see prior discussion here:

Also check the document. If you truly convert the balance to an annuity then the balance should go to zero and you only have the annuity (if plan frozen), or if not frozen, then each year's CB credit is converted into additional annuity benefit.

The RMD is his annuity benefit in the form that he elects. That won't decrease once started but could increase if there are future accruals, which in this case sounds unlikely. Yes you reduce the hypothetical account for the withdrawal paid. Yes you have to preserve the annuity benefit to avoid anti-cut back provisions.