Keith Lowery

Thanks Paul for your commentary. It is much appreciated !

Let me rephrase my question, is it possible to pay the MVA fee out of forfeitures ?

Can forfeitures be allowed to pay for the MVA ?

Sorry. Next time I will look at the BPD.

Ft William doc, 12/31 PYE. Eligibility is age 21, 3 months - elapsed time (not consecutive) and monthly entry. Hire date: 2/25/24 Term date: 4/11/24 Rehire date: 8/22/24 When should this person become eligible ?

Thanks again for everyone's comments. Let me try to clarify my original question. My question was not necessarily the details of exiting a PEP, but rather if anyone had experience with how recordkeepers handle this process of an employer leaving a PEP and no longer having a 401(k) plan. Specifically, do any of them have a solution in place ? The recordkeepers I have worked with indicate they would price the "spin off" as a separate new plan. This would add to the cost of shutting down the plan. Thanks again.

Thanks for the information. I understand the process to leave and terminate from a PEP. However, none of the recordkeepers we deal with have any process of doing this.

Interested to see if anyone has dealt with a recordkeeper that has a solution for a company that wants to leave their PEP. My understanding of the process is they must establish a new plan, transfer to the new plan, then terminate the plan. The recordkeepers that we have PEPs with currently do not have a viable solution for this process. Curious to see if anyone else is running into this issue and if you have a work around. Thanks!

Is there a DFVCP fee for a late 5500 filing that has no assets or lives ? I have a PEP with a Dec 2022 effective date. However, no plans joined the PEP until 2023. Thanks!

Thanks.

For a PEP with less than 100 account balances, they are allowed to file the 5500-SF, correct ? I am getting push back that they must file Form 5500 with Schedule I. Thoughts ?

My understanding is the mid-year safe harbor change can't be done after August 31st (assuming 12/31 PYE) because of the SH notice requirement....given the 3 month requirement for the creation of the new SH plan. If the new 401(k) SH plan is a nonelective contribution, is a Safe Harbor notice still required ? Thx!

Yes, that does help. Thanks for everyone's input. Much appreciated.

To clarify, the employee elected 15% from his paycheck. These funds were never withheld from his paycheck. What would show on his W-2 ?

401(k) plan where employer missed depositing deferrals for an employee. The missed employee deferrals totaled $30,500. A QNEC will be made to correct this plus a match and earnings. Can he continue to defer to the plan and receive a match since we are still in the same plan year ? Thanks!