Hello,

My Series 7 and 63 licenses will expire at the end of January 2011 if I don't get a job in the financial services world that will sponsor them.

Is there any way that FINRA will grant me an an extension to keep my licenses parked beyond two years like say for 3 months? I have heard there is a way to request this but I have no idea how or even if I can.

I appreciate any help from anyone on this board regarding this matter.

Hello,

My Series 7 and 63 licenses will expire at the end of January 2011 if I don't get a job in the financial services world that will sponsor them.

Is there any way that FINRA will grant me an an extension to keep my licenses parked beyond two years like say for 3 months? I have heard there is a way to request this but I have no idea how or even if I can.

I appreciate any help from anyone on this board regarding this matter.

Can a 401(k) plan participant designate the specific investments, within the qualifying money source (i.e. Profit Sharing or Rollover accounts), to convert to an in-plan Roth account?

Does anyone know of a good company to work with that offers nondiscretionary trustee services? We currently use a place when requested by a client but they have not been good to work with. Most of the time we need the service because a client does not have a US citizen as trustee.

There are a number of surveys and analyses of funded status on a FAS 87 accounting basis (status of Fortune 1000 companies, etc.). Are there any similar surveys or studies on a PPA funded basis? Thanks.

If the employer wants to use the Non-elective Safe Harbor contribution as a tax deduction, does the contribution have to be made by the tax filing deadline or does the 12/31 deadline apply for a calendar year plan? I know the contribution must be made by 12/31 regardless of the deductibility-

Two partners in a profit sharing plan. They are each others beneficiary.

One partner dies. His first RMD would be in 2010. Beneficiary wants to take a partial distribution that would be significantly more than the RMD, then roll over the balance into a beneficiary IRA.

RMD is 11,000. He will take 50,000 total.

The RMD portion is not subject to mandatory withholding. What about the balance?

Article v. C. further direct the Trustee to "distribute the proceeds of the settlors bank IRA to the residual trust".

my banks trust department position is "From the plain language of "proceeds", the trust document directs a cash out of the IRA be4 it is transferred to the residual trust. the bank wants after tax money to go to residual trust . end result- large tax is due now.

do you agree with the banks interpretation of the top sentance. everywhere i read from private letter rulings and on seem to permit non-spouse beneficiaries to open inherited iras thereby keeping funds under the umbrella of the ira.

please ask if you need more info. im not a professional but have a real life situation.

PS. is the banks interpretation of the phrase " ira proceeds" even applicable in the context of my situation? just their definition seems strange.

since I was asked this, and I don't deal with these, I'll go to the experts.

Can a husband and wife who own a business but pay themselves via a 1099 put in a SEP? If so, can they contribute the maximum ?

A partnership sponsors a DB and a 401k.

The partnership is owned by two corporations. Each own 50% of the partnership.

Each corporation has one employee (the owner of each corporation). They are related employers so each corporation adopted the plans as participating employers.

Each corporation (as a participating employer) deducts the contributions that are funded for its employees (just the owners of those corporations).

The participating employer section of the DB is somewhat ambiguous on contributions. However, it appears to indicate that all compensation paid through all related employers is considered.

Each of these participants have w-2 salary from their corporations of more than $245K and each have DB contributions of about $75k. One participant has no contributions in the 401(k) (no SD and no ER contribs.). The other would like to contribute $54,500 to the 401(k). Something tells me he must be limited to a 6% employer contribution in the 401(k). But then again, the participating employer section of the document seems to indicate that compensation from all related employers is considered.

Does anyone have any insight on this?

Thanks much.

Say a plan sponsor made a non deductible contribution for 2009 of 100k.

When computing max deduction under 404(o) in 2010 are the assets reduced by the 100k? It appears not.

So if the assets are not reduced and the max deduction is 400k then it would appear that the prior year 100k would be applied and then an additional 300k to add up to 400k.

And if they did not make a 100k non deductible contribution for 2009 the 2010 maximum would have been 500k instead of 400k due to a lower asset value, thus a 100k deduction is potentially lost.

Pre PPA you would reduce assets by carryover and thus plan would not lose out on 100k deduction.

Any other interpretations?

And re: the 430(i) alternative limit calculation for a small plan. Does the at-risk calculation reflect only the additional actuarial assumptions or the loading factor too?

thanks

Section R of IRS Notice 2010-83, Restrictions on Plan Amendments Increasing Benefits, is a bit confusing. We would appreciate hearing how others are interpretting the limitation period on benefit restrcitions if a plan adopted the special amortization rule or either of the components of the special asset valuation rule.

Section R of IRS Notice 2010-83, Restrictions on Plan Amendments Increasing Benefits, is a bit confusing. We would appreciate hearing how others are interpretting the limitation period on benefit restrcitions if a plan adopted the special amortization rule or either of the components of the special asset valuation rule.

Feedback welcome.

Thanks

Appleby_Beneficiary_portability_Page_5.pdf

It appears one of our terminated large plans will not have evryone paid out until after the first of the year. Beacuse the participant count is over 100, an audit will be required for this short year final 5500-correct?

An IRA owner is allowed to compute their RMD for each IRA and withdraw the total amount from a single IRA. If one of the IRA's is an inherited IRA (nonspouse) can the total RMD come out of that IRA?

Does anyone know if there is a way for an employer to not provide matching dollars on any bonus money paid to participants and then deferred into the 401k plan? The plan is a QACA safe harbor with a non-elective contribution but it also has a separate discretionary PS match and the PS match is what the employer would like to avoid for any bonuses. Compensation is now defined to include all W2 money so maybe we can amend the compensation definition and also somehow exclude bonuses from being defeferred into the plan or somehow eliminate matching on any bonus money? Is there a way to do this?

I've been looking for some time now for a meaningful discussion addressing the impact of health care reform on wrap documents, specifically whether an employer adopting a wrap plan needs to adopt health care reform related amendments prior to the end of 2010, and whether the wrap plan in and of itself (as opposed to the underlying health plan(s)/insurance contract(s)) is required to make a grandfathering decision (and everything that flows from that decision).

I haven't been able to find much - I'd appreciate any thoughts/insights that anyone has had or determinations made regarding what employers with wrap plans are required to do prior to year end.

Participant age 65 is getting divorced from 80 year old spouse. Participant started pension 15 years ago on Joint & 100% survivor basis. Monthly amount is $1,000.

(1) If QDRO assigns 1/2 monthly pension, then participant gets $500 and spouse gets $500 and the Plan wins because 500 ax + 500 ay < 1000 (ax + ay - axy)

(2) If QDRO assigns value, then spouse should get 500 (ax + ay - axy) / ay and member should get 500 (ax + ay -axy) / ax but can this be done without a plan amendment?

Comments welcome.

An owner participant begins RMD's on 4/1/2011 in the form of a term certain annuity with a 26 year certain period. The participant is still employed and still accruing benefits. The plan provides for an insured death benefit. If the participant dies prior to actually retiring, will the beneficiary still receive the proceeds of the insurance policy as well as the remaining payments on the annuity? Are they even eligible for the pre-retirement death benefit after RMD benefits have commenced?

The document defines the pre-retirement death benefit as the greater of policy proceeds plus theoretical reserve, so I find it hard to believe that the beneficiary would get both.