austin3515

That's the table export that comes out of Relius. That's just for the APR's. You don't need a table to project todays allocation to age 65, even for a 20 year old. I think that is what you are asking anyway. So for a 20 year old to increase for 8.5% interes to age 65 is not what the APR tables are for, it's to determine the size of the annuity at normal retirement age.

The OP did not say it was a safe harbor plan though, and the 3 month plan year rule is only applicabe to safe harbor plans.

I'm not following how that document is written so can;t comment. The waiver talks about "Employees" (not Eligible Employees) so it seems to me that if you use this document to exclude Union Employees but then use this waiver, the Union people would be eligible. I can;t imagine anyone would want that. So maybe I'm missing something. Although: "To allow Employees hired on a specified date to enter the Plan without regard to the minimum age and/or service conditions," It doesn;t say without regard to the Eligible Employee Definition. Boy if I were them I would have used the words Eligible Employee though in that section. I guess I quit now. I think we are on the same page.

David D - In every document I have ever seen, the waiver is regarding Initial Eligibility (i.e., wait and service provisions). If someone elects to exclude union people, but they waive eligibility, that never means all of the union people are eligible on the first day just because they were employed, The waiver means any non-union employees who have not met age and service are eligible right away. Two key statements: "The owner deferred, but because all employees work <1,000 hours per year, they were told that the employees are all ineligible" "the business only started in 2025" If the business was new in 2025, the only way the owner is eligble but not the employees is if the "Exclude" option was used to Exclude part-timers with less than 1,000 hours. So I think someone had a pretty cool idea on plan design AND communicated the design correctly, but failed to realize that coverage would never pass. I hope Albany tells us which one it was :).

The way I read the initial post, the excluded employees are not excluded because they did not meet eligibility - they were excluded as a class. The "initial eligibility waivers" do NOT waive excluded class provisions. Hopefully the OP can clarify because this is a super critical distinction. If they are eligible for the plan, everyone has a missed deferral. If they are not eligible for the plan you only need to bring enough people to pass coverage which might be a way smaller group.

The "exclude employees > 1,000 hours" exclusion is usually in the definition of Eligible Employee and is NOT an eligibility condition. So if eligibility requirements were wiaved, that does not eliminate an exclusion. You have no ADP issues because the plan can carve out HCe's even if the are OE's into the ADP test, and in your case only one HCE exists. But then we get to coverage. There is no early participation rule for coverage testing. So now we need to bring in a bunch of people to pass coverage. Your plan is top-heavy so they all need the 3% THM. Then you also have a missed deferral opportunity for those people as well. I would go with 3%. So that's 6% for them. This is just back of a napkin, but what a mess. Hopefully it's a small number of employees.

An super good actuary told me that the best approach is individual annuity female 83, 8.5 pre, and 7.5 post. the 8.5 pre is to get the most bang for the buck on the age disparity between the young and the old. iaf 83 and 7.5 post was to get the lowest possible EBARS because imputing disparity is more effective at the lower rates (just like it is in a regular integration calc— I.e. you can double anything below 5.7%).

Oh yes indeed. Because if the median of the averages exceeds the regression analysis of q with x being equal to z. that's the other way to do it 🤣🤣🤣

This is not the APR's though, which is what is needed. Mine includes the APR's.

I recently did a major upgrade to my "Calculator" and downloaded all of the tables from Relius. 7.5, 8 and 8.5 post retirement, and every "approved" table (so its like 21 columns or something. I share it here for the good of the community. Nothing proprietary about mortality tables! I can tell you I spent a LOT of time verifying accuracy, etc. before I added it to my calculator. And I make it a habit of using my tool as a starting point, and then verifying it matches the software as a finalizing step (I now use FT William). So I can tell you their tight but you need to prove on your own before you start using them because I accept zero responsibility for their accuracy. i.e., don't just take my word for it. All APRs (7.5, 8 and 8.5).csv

I think the takeaway here is, if you setup a plan after July 31st you are not missing any 5500 filing deadlines. If you set up a plan before 7/31st, you do you! Me personally, I would never file something with the government that I wasn't required to file. That's just me and how I was raised.

Correct. The reason for the exception is you can set up a Plan under SECURE after July 31st, thus making it impossible to file an extension.

Voya is actually the only one I reached out to so far 👍 Hopefully they will come through for us!

Maybe you can give me the name of one of each. Perhaps they have the requisite expertise to talk to them.

Tax exempt agency, created by a state statute.

Trying to help an acquaintance find a cheap option for opening a 457b for a tiny quasi-government agency. Anyone have any ideas?

Client received CP283 notice. I know we can still file under DFVC Program and request abatement, my question is, has anyone done that recently and does it still generally work? I know never say never but curious if others have done it recently.

As we all know the IRS got rid of the "Flexible" match where you can just say the match is discretionary and come up with any formula operationally. The FT document has an option for a discretionary match (8a) where the options are "as a uniform percentage of Matched Employee Contributions" (which is of course the normal one) or "as a flat dollar amount for each Participant, which of course we don't really see. Here is my issue. I cannot find anywhere that, with respect to the "uniform percentage of Matched Employee Contributions", I am able to cap the Matched Employee Contributions at X%. So everyone has a match expressed as X% of the first Y% contributed (e.g., 50% of the first 6%). I cannot find anywhere in this document that I can include the Y% / 6% cap in my examples. Has anyone noticed this? People always say, "you can get to the same outcome if you use the maximum match section and cap the match at 3%" - that only works if you never change the match so it's not a great solution. To be honest, this was a real issue for me in the FT 401k plan as well, Cycle 3. I am very curious to know if they finaly figured this out for Cycle 4. As a sanity check I am just really hopeful other people have seen this too? Or maybe I'm missing something?

You’re circumventing payroll taxes is the bigger issue than retirement plans (both are big but the IRS wants its money. Employers are less of a credit risk than individuals

if they had 1099 income they should be able to do a Roth IRA. So maybe everyone gets what they want? We know clients are usually wrong when they code people as 1099-MISC employees but its not our problem. I'll bet all of our service agreements specify it's not our responsibility to make that determination.

That's what I do most of the time, with all of the same explanations, but some executives still want it. I've even had business owners want themselves to be the trustees of the trust to give the program more credibility (what do they care, they were never going to take it away anyway). But for sure 8 or 9 out of 10 I am just doing corporate brokerage accounts. It's the last 2 where I figure there must be a solution. It's not that complicated.

There is no lack of trust here, no one is worried about this, they just want to know what the right answer is.

Truth be told this was a question from an auditor I am friends with, so I don't even know the identity! This is what I can tell you. I have been a TPA for about a million years. Partners fund their contributions at any time through the date of their 1040 due date (or partnership return if earlier) and the words "late deposit" never left my lips in those conversations. And I don't think I missed anything by not mentioning it. Tell me I'm wrong :).

Anyone know of a brokerage account solution, no advisor attached, for these types of plans? I need a solution where we can have it registered to the trustee of a rabbi trust. In my experience advisors do not like working on these because the opportunity for accumulation is retty low. So I'm looking for a Fidelity/Charles Schwab type retail account where we can just fill out an application and open the account, no advisor comp. Anyone know of a solution?

https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/advisory-opinions/1999-04a I saw this but I cannot figure out where the relevant part is. Anyone? Also this is the 100% owner of the business. I see the point of course about PriceWaterhouseCoopers (just to use an example that makes sense to all of us) withholding partners money and holding onto for it for 6 months... But this is definitely that.