I am looking for a sample investment policy for allowing a self-directed brokerage account. Would appreciate any references.

I filed my return in August and now would like to recharaterize my Roth due to how the market has affected my Roth. Is this possible or must I have filed by April 15th? If it possible is the only thisng I would lose would be the 4 year spread?

Our TPA & consulting firm has been trading on the NSCC platform by going through Columbus Circle. We ran into a few problems and are now looking at Mid Atlantic. Does anyone out there have any experience with Mid Atlantic? I would love to hear from you. Thanks.

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401(k) Plan was implemented 7/1/98. Top heavy determination indicates that plan is top heavy for initial plan year (1998).

Question: Re: minimum top heavy contribution allocation, are you required to use full-year compensation (as defined in 415©(3)) even though the plan was not in effect for the entire year?

Has anyone ever heard of a "177A pension plan". Never heard of anything like this. Could this have something to do with a federal plan, e.g., Railroad Retirement. Any help would be appreciated.

Our client has a 401(k)/403(B) plan for its employees, to which it also makes employer contributions. If the participant fails to sign an election form, employer contributions are placed in a suspense account until the form is completed. The suspense account earns no interest. The employer would like its contributions to earn some interest until the employee completes the election and investment option forms. The broker-dealer that services the plan has indicated the SEC prevents money from being invested prior to the receipt of employee forms. Can anyone point me in the right direction with regard to SEC rules that govern broker-dealer conduct so I can see verify the broker-dealers conclusion.

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A person has the following pays:

1995 50,000

1996 60,000

1997 70,000

1998 55,000 (terminated on 10/1/98)

plan uses a 3 yr avg.

Is it legal to ignore the 1998 compensation in computing avg salary, eventhough it would produce a higher avg, because the plan says it only uses complete years worked? Or is it really just based on what the plan says? Interested in other opinions.

Plan has the principal residence safe harbor provision.

Several years ago Participant used a hardship distribution to buy a two family house. Participant now wants to move out of the two family house and use it as rental property and take a hardship distribution to purchase a four family house that he will live in. Using the hardship distribution to purchase the 4 family house would meet the requirements of the safe harbor on its face, that is, the money will be used to purchase a principal residence. My sense, however, is that this would be in violation of the Safe Harbor Reg (Reg §1.401(k)-1(d)(iv)(A)(2)). I do not think the intent behind the principal residence safe harbor was to permit participants to keep buying residences.

Does anyone have an opinion on this?

How should "separate account GICs, synthetic GICs, and BICs be reported on the Form 5500 that is scheduled to be in effect for 1999 plan year reporting. These are not held in insurance company general accounts.

I have heard of various terms for "new comparability" plans - third-generation, qualified bonus, super-integrated, etc. I had not heard the term "super comparability" before. Can someone explain what a "super comparability" plan is and where this term came from? Thanks.

I noticed that in Noel Ice's Excel template for the 706 Worksheet the IRD deduction is calculated based upon the average estate tax rather than the marginal estate tax. I also noticed that the prior accumulated taxable gifts were not used in the total calculation. Shouldn't the IRD deduction be based upon the marginal estate tax increase?

does anyone have any old tests they could share?

If a plan has not yet adopted GATT and is computing a lump sum, is the mortality table used required to be 1) mortality defined in the plan document, 2) old PBGC adjusted UP84 mortality, or 3) can it be either 1) or 2)?

I have a client that was fromed on June 1, 1997. For the 1998 plan year we are looking back to 1997 for HCE determination. Do we need to prorate the comp. for 1997 since the company was formed in June or do we look at the actual comp. for our HCE determination.

Any help would be greatly appreciated.

I have a for-profit utility service that did have a Money Purchase Pension Plan and now wants to switch to a 401(k) Plan. Can a Utility Service sponser a 401(k) Plan or does it have to be a 403(B) or 457 Plan?

Rev. Proc 87-27 states: 6. All actions necessary to implement the change of plan year, including plan amendment and a resolution of the Board of Directors (if applicable), have been taken on or before the last day of the short period.

Does anyone know if anything has superceded Rev. Proc. 87-27, or is the deadline for changing the plan year still the last day of the short plan year?

I am looking for Organisations which offer benefit adminstration/wage and salary courses, short term or certificate. I am based out of Minneapolis right now.

Thanks for all your help

A very old loan still in existence was made to a participant and the loan is a general asset of the plan. Both the plan and the participant would like to change the loan so that it falls under the current participant loan rules, so that repayments go into a participant loan account rather than into the general assets of the plan. The plan is a 401(k) profit sharing plan. The plan allows only one participant loan at a time. The current outstanding balance is about $10,000. What is the best way, if any, for the plan and participant to make this change?

Are 415 limits on annual additions prorated for a short initial plan year? Situation: Employer is on a fiscal year from 4/1-3/31. Employer wants to establish a profit sharing plan with an initial plan year from 1/1/2000-3/31/2000. If the limitation year is defined as the 12-month period ending on 3/31, then is the full 415 limit available for the initial plan year, or are those limits reduced because of the short initial plan year?

My 14 year old son has generated $700 in earnings from a part time job working as a house and pet sitter while folks are gone out of town. He would like to open a Roth IRA by investing $500 of his earnings in a mutual fund account. Given the fact that he has earned income, is there any reason he could not start a Roth IRA at age 14?