In April 2024, Vanguard told customers it was ending recordkeeping and plan-document services for retirement plans served by Vanguard’s Individual 401(k) and other small-business lines. (Many followed Vanguard’s suggestion to transition to Ascensus.)

In 2026, Edward Jones and Morgan Stanley each told customers it will no longer provide plan-document services for “Solo 401(k)” retirement plans.

Do you think these service exits set up a business opportunity for a TPA?

Or, are many micro-business plan sponsors not a good client for a TPA?

What do you look for in evaluating whether you’d accept or decline a one-participant or micro-business plan as your client?

We have a plan where the ownership is a trust.

I believe this means the trustees of the trust are deemed to be the owners - is that correct?

So if an employee is a trustee of the the trust they are deemed to be a 5% owner, correct?

Does it matter if there is more than one trustee?  For instance if there are 4 are the all deemed to be 25% owners of the trust?  Or are they all 100% - or does it vary?

I don't know what I don't know here.

finishing an audit for plan year 2023 the auditors want a corrected 1099r completed for tax year 2019 (showing a taxable distribution of $75000 on behalf of a participant)

is this possible to complete?  I can prepare the 2019 1099r form but cannot complete find a 1096 for 2019.  

does this qualify as an acceptable filing?;  is the participant liable for tax payments on a distribution that was made 7 years ago?

I'm  not sure the irs auditor/supervisor are aware of all tax liabilities since the auditor reminded me that participants unable to be located can have their full balances remitted via 100% withholding tax to the IRS.....

I have never given a client the option, but a financial advisor is asking the question...

Can the plan sponsor decide year to year if their plan is a SH plan or not?  and if so, how does this work?

I know that to be a SH Match, for an existing plan they must decide prior to 1/1 of the new plan year... but a plan can switch mid year to a SH plan by 12/31 if they add a 3% NEC SH contribution (after 12/31 if the NEC is 4%).  Ok, say they did that... that would be amending the plan which would mean the plan is now a SH NEC plan moving forward.  To go back to a non-SH plan, well, another amendment switching the plan back?   I'm getting dizzy just thinking of amending the plan each year.  But.. is that how it is done?  Or maybe I am totally off... you can't do this year to year.  

If I am putting a client into a brand new DC prototype Plan Document, what Amendments/Addendums should be in their Document package??

I'm getting myself confused, maybe I'm just tired, ha ha. I'm BRAND NEW to FTWilliam; leaving another software that I've used for almost 3 decades!

When I print the Adoption Agreement in the FTWilliam system, the following are part of that:

• the SECURE 2.0 Addendum 2026,
• the SECURE 2.0 Addendum 2025, and
• the SECURE/CARES/CAA Addendum.

It seems VERY redundant to send a client each of these 3 Addendums, but is that accurate? Or does just the '2026' version go with a Document package? Again, my brain may just be revolting against the transition tasks, and I have researched this but cannot find a clear (dumbed down!) answer.

Thanks guys.

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We know we can retroactively adopt plans and we can also retroactively improve benefits. However, if a controlled group member wanted to retroactively join the existing plan of a related controlled group member would this fall under one of the two scenarios(i.e., IRC 401(b)(2) or (b)(3)?

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Could a plan sponsored by a sole proprietorship be amended to include a partnership for the prior plan year if the partnership adopts the plan before the tax filing due date?

Hi

Law firm.

CB plan, effective 2024. For 2024 had 15 active participants with 0% vesting - vesting effective with inception of the plan.

During 2025 exceeded 25 active participants (26 in total), again all with 0% vested balances.

During 2026 dropped to 20 active participants. No partial termination issues. It will never exceed 20 again.

So, during 2025, plan is covered by PBGC and will be so for 2026 and all future years, at least according to PBGC rules that I am aware of.

Any way out of this, is there anything I can do? Am I missing an option here? Really sucks that for 1 year only they are paying the price for it.

Thanks

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Just looking for some clarification and confirmation...

The Roth catchup requirement rule is that if you earned $150K of W2 income the previous year then your catchup deferrals must be Roth deferrals.    Is there something that I can show a CPA clarifying reported K1 income?  I googled and found someone saying the rule points strictly to W2 income..

Thanks

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I've filed the 5500-EZ for my Solo401k for tax years 2021 (once it hit $250k) through 2025. I just noticed that the effective original date is 1/1/18, but I've been putting 1/1/19 on all the 5500-EZ forms from 2021 to 2025.

Now, I'm considering opening up a Mega Backdoor Roth, and MySolo401k.net has to restate the Solo401k plan and needs the original effective date (I called E-Trade to ask and that's how I noticed the discrepancy).

I've read horror stories on here about people amending their 5500-EZ forms that have been filed on time/yearly and being slapped (it seems automatically?) with late penalties of $150,000 per year, such as here: 

1. What do I do? Let sleeping dogs lie and continue putting the 1/1/19 date on the yearly 5500-EZ forms moving forward? If I put 1/1/18 on the 5500-EZ form for next year, will that trigger some kind of alert on the IRS' end with the associated $150,000 yearly penalties?

2. Do I need to amend every 5500-EZ from 2021 through 2025?

3. Does the plan restatement by Solo401k.net get sent to the IRS in any way or just to E-trade?

Appreciate tips/advice! Thanks!

What are the issues if plan eligibility requirements are liberalized to accommodate a family member and then switched back at a later point in time? 

Patrick Tool LLC employer is participating in Business 401(k) Plan (MEP plan) effective 01/01/2023. During mid of 2025, Patrick Tool LLC decided to establish new plan and spin off from Business 401(k) Plan and completed the participants cessation on 31/07/2025 and establish new plan as Patrick Tool 401(k) Plan as effective date of 08/01/2025. The first return, it will be short plan year. 

For the compliance testing whether we required to do two separate testing for two period like 01/01/2025 to 07/31/2025 and 08/01/2025 to 12/31/2025.

Since the employer is same whether we have to aggregate both the period data and required to do compliance testing for full plan year under Patrick Tool 401(k) Plan. Even though the plan effective is mid of the plan year, we have to complete the testing based on full year compensation and contribution or else based on the short plan year.

Can the employer amend the plan to add Roth if the 403b plan is structured as not subject to ERISA under the limited involvement safe harbor regulation 2510-3-2(f)? If Roth is not added, then any high earner over the FICA limit cannot do catch-ups. Due to this SECURE 2.0 requirement, I would think adding Roth could be permitted. Any thoughts?