For ERISA-governed individual-account retirement plans that provide participant-directed investment, many such plans’ administrators furnish disclosures to follow 29 C.F.R. § 2550.404a-5.

That rule calls one to show specified comparisons of a designated investment alternative’s past-performance returns to those of “an appropriate broad-based securities market index[.]” 29 C.F.R. § 2550.404a-5(d)(1)(iii) https://www.ecfr.gov/current/title-29/part-2550/section-2550.404a-5#p-2550.404a-5(d)(1)(iii).

Although Congress in 2022 directed the Secretary of Labor to “promulgate regulations” about a benchmark one may use when an investment alternative “contains a mix of asset classes”, no such rule has been made or even proposed.

Recognizing that (at least for smaller plans) many recordkeepers and third-party administrators assemble 404a-5 disclosures with little or no guidance from a customer plan administrator, what are service providers using as the benchmark for target-year funds?

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Beginning of Plan Year had 2 participants, 1 owner, and 1 terminated employee.

Terminated employee took a full distribution during the year, so that..

End of the Year has owner only and can now file Form 5500-EZ, except..

Assets are under $250,000.

I think better off the plan files 5500-ez anyway but never encountered this situation before.

I'm just curious if anyone has had a 5500-EZ filer who was required to file electronically because they have at least 10 electronic returns (as my understanding effective 1/1/24)?

Does the IRS actually check this?

I should know this, but......

John owns 13% of company A; 0% of company B

Joe  owns 13% of company A; 0% of company B

ABC company owns 74% of company A; 100% of company B

Does a controlled group exist between Company A and B.  More specifically, can the 401k plans for A and B operate independently of each other?

Thank you

I have a situation where mistaken contributions were made to a retiree-only HRA.  I'm familiar with IRS guidance on recovery of mistaken HSA contributions but cannot find anything on mistaken HRA contributions.  The custodian of the HRA is claiming the HSA rules apply but I'm wondering if there is any other applicable guidance for mistaken HRA contributions.

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Hello,

We had a salaried employee who resigned recently, but HR was not notified in advance, which caused the employee to receive a full paycheck in error. We are working on recovering the overpayment, but this employee also had Roth deferrals that has already been funded to his retirement account. Our record keeper suggested we remove the excess contribution from the participants account, which we plan to do.? I haven’t heard back as to how to employee is going to repay us (employer) back, but I’m assuming it is via a check. My question- is this something we should correct via payroll as well since we are reversing the contributions from his retirement account?

Hi, this question was bouncing around the office last week and thought I'd ask around here for opinions.

Can a DB plan sponsor in the LA fire disaster area still satisfy 2024 minimum funding and get their 2024 deduction for contributions made 9/16/25-10/15/25? 

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We have a Cash Balance Plan that terminated in 2023.  The bulk of the distributions were completed by 12/31/23, with a few finalized in 2024.

All of the 2023 distributions were reported on the 2023 Form 5500, but it turns out 3 checks get returned as undeposited and the money was back in the account as of 12/31/24 (it is the only money that is sitting there, totaling under $3k).  So how do we handle that in terms of the Form 5500:

1. Do we have to show it on the Form 5500?  The participants were sent 1099-R for the distributions in 2024 (for 2023) and it was already reported as distributed on the Form 5500?
2. If we do have to report it on the Form 5500, how is it shown as coming back into the Plan?  It's not really a contribution...
3. If a Form 5500 is required, is a Schedule SB also required?  Or is it just the SF at this point?

Thanks everyone.  This isn't a situation I've run into before.  The Plan is to have the money rolled into an IRA on the participant's behalf by 12/31/25, but trying to handle the '24 Form 5500 first.

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If there is a participant (or even employee) who terminated in 2020 with zero balance, should they be reported on the 8955-SSA after receiving a corrective QNEC deposit in 2024? Should they be reported at all? Form instructions reference when the participant separates from service - 1) some of these employees were never participants and 2) they did not have a balance at the time they terminated so I don't think filing amended forms make sense either. Logic makes me want to report them code A so there is reporting of a remaining balance, but I know logic doesn't always apply. 

Form Instructions state: 

When To Report a Separated Participant In general, for a plan to which only one employer contributes, a participant must be reported on Form 8955-SSA if: 1. The participant separates from service covered by the plan in a plan year, and 2. The participant is entitled to a deferred vested benefit under the plan. In general, information on the deferred vested retirement benefit of a plan participant must be filed no later than on the Form 8955-SSA filed for the plan year following the plan year in which the participant separates from service covered by the plan. However, you can report a deferred vested participant on the Form 8955-SSA filed for the plan year in which the participant separates from service under the plan if you want to report earlier. 

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Any thoughts on how the last week of the season will be impacted now that TE/GE has officially furloughed what appears to the the majority of their staff? 

Just curious what musing people have now that we are crossing the bridge. 

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