Coleboy1

LOL...because I wasn't thinking when I wrote that! LOL!

I didn't think I could restate the MPP as a PSP. There will be no deferrals allowed. Just a straight PSP. If I can really just restate the MPP as a PSP then that would be the easiest. Thank you!

We have a money purchase plan that the client wants to merge into an new profit sharing plan effective 1/1/2026. Since the psp is new, does it need to have the auto enrollment provisions? Or because of it being a merged plan, it won't need those auto enrollment provisions? Does anyone have any examples of a merger agreement that I can use? Is there anything else that is needed? The participant notices will be going out.

We are in the process of taking over a 401(k) SH Plan. The adoption agreement from the current TPA is showing this under eligibility exclusions: Has anyone else come across this? It's rather concerning.

I was also questioning how they failed. we are just taking over this plan for 2025. ADP hasn't released the testing results to us yet so I have nothing to show you. I am only going on what my boss said to me yesterday. Apparently there are many part timers who only work a few weekends a year as it's a theater group. I will gladly share the number when I get them. Thank you!

We have just taken over a 401(k) plan with a safe harbor match. The plan's eligibility has no age or service requirement. Union employees as well as part time employees as a class are excluded.. In previous years, the plan has failed the minimum coverage tests. Now, for 2025, the client wants to change the eligibility to 3 months and 250 hours of service beginning 10/01/2025. Anyone hired on or after that date would be subject to the new eligibility. They are looking for ways this late in the year to avoid failing the minimum coverage test for 2025. I don't think the above is feasible and would help. Any insights would be appreciated.

The deadline was 9/15. The recordkeeper rejected the contribution file due to the fact that there were some people not on the system but were on the contribution file. The people were added but the recordkeeper's system takes a day or 2 to recognize the newly added people. Hence the contribution could not be made.

The contribution for a money purchase plan was made 2 days late. Will the client be subjected to a penalty for being only 2 days late?

A new trustee was appointed. I was just curious as to whether the actual documentation had to say that the previous trustee was being removed. ie Due to his demise, Mr. S is being removed as trustee and Mr. W will be appointed as the new trustee. My signed documentation doesn't say that but my boss is questioning as to why it didn't.

One of my clients was killed. He was also the trustee of the 401k plan. A new trustee was appointed and an amendment was done. The resolution did not address removing the old trustee as I didn't think it needed to be addressed since he was deceased. Shold I have had some language addressing the removal of the deceased person as trustee?

Can someone tell me the steps to amending the money purchase plan to become a PSP? Or do I have to amend the MPP to bring the contribution to 0% and set up a separate PSP and move the assets over?

I agree with terminating the MPP but the higher powers don't want that. Can the MPP be amended to a PSP?

That's what I thought but my co-worker was disagreeing with me. I didn't know if something had changed in the rules as it's been a while since I've really work with MP plans. I just got this assigned to me in May.

Our client currently has a money purchase plan. They no longer want the money purchase plan and want to replace it with a 403(b) plan. Would it be considered a merger? Or do we have to terminate the MP plan? Are there any special considerations when doing this?

Even though the plan has immediate eligibility with o hours requirement?

Client has a Safe Harbor Match plan with immediate eligibility. They exclude part-time employees as there are many who work just a few hours a year due to the type of work. ie ushers, etc. Plan has failed the minimum coverage test. How can this be prevented from happening in future years? Any ideas would be appreciated.

A participant reaches retirement age. She has never worked 1000 hours to earn any vesting credit, Would she then be 100% vested since she's reached retirement age?

I'm working on a 2023 5500 large plan filing. Plan is an MEP so I have to complete the new MEP schedule. In Part II, I have more employers than I have space for. Do I add a 2nd MEP schedule? Or do I just add a spreadsheet as in years prior to accommodate everyone? Thank you.

An RMD was requested on 12/29/2023. The fund company didn't process it until 1/2/2024. They said a 2024 1099-R will be generated since the distribution wasn't actually done until 2024. How is the handled by the participant regarding his taxes? He is expected to reflect a 2023 RMD but will not have a 1099-R to show for it. in 2024, he will end up with 2 1099-R's.

I forgot to mention that eligibility for these 2 plans is age 21 and 2 months of service. Does that make a difference with the per diem situation?

Oh, how I wish I was old enough to retire! My old brain can't handle these SECURE 2.0 items! I have 2 plans that exclude per diem employees. Under the LTPT rules becoming effective soon, would these per diem employees now be allowed to participate in the plan?

One of my clients recently received this same letter. I actually spoke with someone at the DOL. She said it was entirely voluntary. That VFCP application looks daunting. I'm going to leave it up to the client as to whether they wish to proceed with it. Most of the information requested is only information that they and I'm not even sure they are willing to do it.

Thank you! That's what I thought but wanted to make sure.

This plan has a triple stack match. If the owner doesn't defer any money for a particular year, does the triple stack match still need to be applied to the NHCE's? Or are they just given the 4% safe harbor?

2 Year Old plan. First year assets were less than 250K. 2nd year they were over. Hence I'm doing the 1st year filing in the plan's 2nd year. Is my beginning balance $0 or do I use the ending balance from the previous year( that was under $250K)?