Keith Lowery

If they want us to do the final work, we will request the census for that short year, and then also the short year for the time they joined the PEP. We do not request an annual census.

RatherBeGolfing....thanks for the response and feedback ! We are seeing this issue more and more and do have difficulties in obtaining prior reports. Plus this just adds additional work on the already full plates of our Consultants.

When a plan in merges into a PEP, as we know, it needs to be shut down with a final year compliance testing and 5500 filing. It has become more common where as soon as the current TPA is notified of the intent to merge into the PEP, they stop their service and fail to complete the final testing and 5500 filing. What recourse does the client have to ensure the current TPA completes the shut down, especially since the fees have been paid for that service ? Besides the new TPA completing the final work, are other solutions available ? Thanks for your time.

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!