A.C.

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.

When reconciling employee deferral/Roth contributions to deposits on an annual basis there is a shortage (and overage) for some participants - but a net shortage overall. When this doesn't tie out to a specific payroll (or at least doesn't appear to since I don't have payroll and deposit detail by paycheck) and the amounts can be small ($4 or $20, for example) - do you report these amounts on the 5500 as late deposits? Would you need to track down the shorted paycheck for lost earnings calculations?

How should the IRS compliance question for nondiscrimination testing for "how the plan intended to satisfy" the requirements for a plan that terminated in a prior plan year? The form instructions say to "Check N/A" if the plan is not required to test for nondiscrimination under Code section 401(k)(3), such as a plan in which no HCE is benefiting. I took a look at this section which discusses safe harbor requirements and saw a statement about the final plan year but it still wasn't clear to me all of the exceptions the form instructions were trying to refer to. There is a reference to the final plan year and says the following: Since the plan year relating to this 5500 is one following the plan termination date and is when the final distributions occurred, would N/A be the appropriate response?