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D, the 100% owner of an S-corp, passed away in 2018.  Ownership of the business passed to D's two sons who worked there (and were already participants) 50/50, and they also happened to be his 50/50 beneficiaries.  D was in RMD payment status, so we've been continuing to calculate his RMD each year and splitting it between the two sons.

Since D passed away pre-SECURE, are there any timing issues I need to worry about for the distribution of D's entire balance?  The post-PPA plan document says that the beneficiaries "may" elect the 5-year rule.

Thanks.

401k/SH match/PS combo with CB plans. Top heavy is provided by DC plan. PS allocation is everyone in their own group. Plans are top heavy.

DC plan eligibility for all sources is age 18 and 6 months with entry 1st of month following completion of 6 months service. CB plan is 21/1 with dual entry.

Gateway is required at 7.5%.

During 2025, the TPA handling the DC plan changed the provisions unbeknownst to me:

• Removed last day and hour requirement for PS contribution
• Made top heavy requirement 5% defined contribution minimum as written in the document for combo plans.

For top heavy, must be employed on last day.

No SECURE 2.0 amendment for "no top heavy for otherwise excludable employees".

A few different questions as I confused myself (do not work with SH match in combo plans in general):

For an HCE but non-key who is excluded from CB plan categorically:

HCE made a deferral and received 4% SH match, but they do not want to allocate any profit sharing. What is the top-heavy requirement? Do I need to provide additional 5% PS allocation?

For non-HCE employees who became eligible during 2025 due to 6 months eligibility:

• Employee enters the plan during the year after 6 months of service
• Terminated before EOY
• Made deferral and received 4% match
• Not in CB due to 1 year wait

Do I need to provide 5% top-heavy PS allocation?

How about for the same employee who was employes at EOY?

I so confused myself here as I have not seen a document written this way.

Thank you

I am not sure if the following is discriminatory, so checking out to be sure.

Company started 2 plans in 2025, both with vesting starting with inception of the plans (both calendar).

Joe terminated later 2025 (he quit) and gets no monies because terminated with 0% vesting in both plans. He was eligible as of 1/1/2025 (DOH goes back a few years)

The company wants to rehire him in 2026 so no break in service but want to exclude him from benefitting under both plans. He would have a unique job category.

So, if they sign an amendment now and then rehire him a few months later (all during 2026), is this a discriminatory approach?

Another approach is to have the amendment signed in 2026 but rehire him in 2027 but that is not what they want to do.

Thank you

I am considering changing software systems (small DC plans, less than 100 1099-Rs per yr) -- going to FT William from Datair. I also have lost my Distributions clerk, so I'm not totally familiar with the IRIS system of filing 1099-Rs yet, but had to go it alone this past January. Forgive me if my question isn't even relevant.

For FT William users does the FT William software integrate somehow with the IRIS system? I might not opt for their "add on" module of 1099-R prep if I have to manually use the IRIS system anyway.

Thanks!

We administer a small profit sharing plan for a physician with a total of 9 participants. All plan assets are pooled.

The physician retired in June 2025. He let us know he retired in November 2025. So we had him terminate the plan effective 12/31/2025.

They had 3 employees terminate employment in late 2024. We provided benefit elections to the 3 and they returned the executed benefit elections. In early May 2025, we provided an instruction letter to the physician who is also the sole trustee of the plan to distribute benefits as the participants had elected. Instead of paying their benefits from plan assets he paid them from his company checking account. This even though the instruction letter specifically told him to pay these benefits from the plan.

At this time we want to wrap up this termination by distributing to all remaining participants. We thought it would be a matter of reimbursing the company from plan assets for those participants that were mistakenly paid from the company checking account. However, we just found out that his company checking account no longer exists.

What would you do?

Thanks.

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Wondering how other TPA's handle this - distribution fees that are paid by the recordkeepers directly from participant accounts to the TPA are generally round numbers.  For some states though, this is revenue that taxes must be paid for as a Sales Tax, and this is indeed detailed in the contract.

We have always passed this on to the plan (ie line item lists distribution fee, and later line item after sales tax calculation lists round paid amount, netting just the tax due payable for that item).

Just had a client complain about this, first time one ever noticed this. 

My company is looking to enhance our Paid Parental Leave. Currently, we provide women & men 4-weeks of FT paid leave. This is on top of the maternity leave provided to the birthing mother. Our company is just about 1000 employees. I would love to get other company data to put into my research if you wouldn't mind sharing! 

Thanks so much!

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