austin3515

I have a limited amount of money to spend on tehcnical resources. I find that the ERISApedia Ask the author service is indispensable. It comes with the qualified Plan eSource. I am curious if others have done a deeper dive into whether or not the ERISApedia publications are comparable to the ERISA Outline Book. IT is hard to imagine not havintg the EOB but I am intrigued by ERISApedia's AI functionality, I just watched a demo. What do you think?

But that's nondiscrimination testing, my question is specifically about coverage testing.

If a plan makes haphazard profit sharing contributions to various people, relying on the "each participant is a separate allocation group" method, must it pass the ratio percentage test for coverage due to the nondiscriminatory classification test in the Average Benefits Test?

As promised. Hopefully people can find them when they need them! I ran these reports off of Relius. Before even opening them I marked as read-only. I then copied and pasted the data into one multi-column spreadsheet where each column has a unique mortality table and interest rate. I just used 7.5, 8 and 8.5. All APRs (7.5, 8 and 8.5).csv 1984 USP 8.5.txt 1984 USP 8.txt 1984 USP 7.5.txt 1983 IAM Female 8.5.txt 1983 IAM Female 8.txt 1983 IAM Female 7.5.txt 1971 IAM Male 8.5.txt 1971 IAM Male 8.txt 1971 IAM Male 7.5.txt 1971 IAM Female 8.5.txt 1971 IAM Female 8.txt 1971 IAM Female 7.5.txt 1971 GAM Male 8.5.txt 1971 GAM Male 8.txt 1971 GAM Male 7.5.txt 1971 GAM Female 8.5.txt 1971 GAM Female 8.txt 1971 GAM Female 7.5.txt 1983 IAM Male - 8.5.txt 1983 IAM Male - 8.txt 1983 IAM Male - 7.5.txt 1983 GAM Male - 8.5.txt 1983 GAM Male - 8.txt 1983 GAM Male - 7.5.txt 1983 GAM Female - 8.5.txt 1983 GAM Female - 8.txt 1983 GAM Female - 7.5.txt

Completely agree. " notice must accurately describe the type and amount of compensation that may be deferred" Key word is "describe".

A literal reading of IRS Notice 2024-02 seems to suggest that each person needs to be told their own personal precise amount of 401(k) remaining for 2025 based on their own YTD SIMPLE IRA Contributions: "Yes. Under § 1.401(k)-3(d)(2)(ii)(D), a notice must accurately describe the type and amount of compensation that may be deferred under the plan for the notice to satisfy the requirements of section 401(k)(12)(D), (13)(E), or (16)(B)(iii) of the Code." 1) the notice is due 30 days before the switch so this is not possible. 2) Nothing in this seems to really suggest that an individualized notice is required for every participant. We are hearing some say that not only do you have to provide them an estimate of what remains for the year 30 days in advance of the switch, but that you also have to follow up after the switch to provide the exact amount available for the year. While I can see the interpretation of the text, to me the spirit of the communication is to disclose the total limit available for the entire year between the SIMPLE and the 401(k). If the above is in fact the requirement, it becomes almost prohibitive in terms of making a transition like this. Small employers cant always get nice Excel exports, and fewer have the ability to do all of the mail merges needed. Please tell me what you guys think!

What are you referring to here? Just want to make sure I didn't miss anything

you'd figure the IRS would just put all of them on their historical pdf chart on their website. But fair point that they are all in the IRS Notice! Thanks!

There were several new "indexed for inflation" figures for SECURE 2.0 that don't seem to be published anywhere. I'm pretty sure these are all indexed: 1) $100,000 threshold for employer contribution credits. 2) $145,000 threshold for Roth catch-up requirement 3) Domestic Violence $10,000 limit? Why aren't these included on any charts/tables? Anyone have a solid source with all of them? Ferenczy seems to have the most (hers has the Domestic Violence one, but not the employer contribution credit one. https://ferenczylaw.com/flashpoint-2025-cost-of-living-adjustments-2-2/

Oh ok I will just skip that one then.

Bri / CB Zeller, THANK YOU BOTH VERY MUCH! I have a testing tool that I use and I want to be able to use any of these available tables so I can recreate the results of any other provider. I will post it here as an attachment when I am done!

Anyone know what this one is called in Relius?

CB, Relius lists so many more than 10. Do you know which 10 are relevant?

Anyone know how to pull them out of Relius? I guess that's what I will have to do.

Maybe I'll put together my own website. APsAPRs.com. I'll sell ads even...

That just seems so hard to believe that these tables used over and over and over by thousands of people every day are not saved somewhere and are rather created from scratch. But I've heard it enough times from y'all to believe it anyway.

Well it would just be 7.5, 8 and 8.5 in my view, LOL, so should be just 30. Is there anywhere that just has a bunch of them? IT's just hard to believe there is not a repository for any of these things. It seems unlikley that every actuary is building these APR tables on their own every time. I guess its possible of course. Anyway I thought I would give it a try out here...

There must be some website where I can download the APRs for cross-testing, right? There should be tables for each mortality table and different interest rates. I know I can export them one at a time out of Relius but I am assuming some website has them somewhere?

To me it is a) taxable and b) a fringe, so the stretch is NOT calling it a taxable fringe in my view. If your base defintion of pay is W-2 (which is always my preferences since there is oodles of guidance on goes in Box 1 of W2) then this is a very easy call in my opinion.

That is so cool!

Please respond, I am very curious to know if there is a consensus on how the DOL's new program will be used!

My understanding is there is an existential threat here, costs must be cut, and some ADP refunds is the least of anyone's concenrs. But 100% we need to run ADP testing. Glad you agree! I will propose this and if they are interested I'll probably submit this to ERISApedia Q&A service before I start doing amendments. But thanks!!

3% SHNEC Safe Harbor Plan. Client wants to discontinue the SHNEC but a) the keys have already made substantial 401k, and b) they are top-heavy. Can we discontinue the SHNEC as of April 30th (after providing the 30 days notice of course) and coincidentally create a short plan year ending 4/30/2025, and remain on a 4/30 plan year end for the foreseeable future? I'll be darned if that doesn't work. I think it does... Otherwise he has to terminate the plan and everyone loses (because terminating is the only way to stop the top-heavy minimum). Of course all keys would be told to stop doing 401k (in fact I have made it my practice to exclude keys from the plan by design (I called it a top-heavy inoculation).

Has anyone heard whether or not payroll companies will issue 1099rs for Roth employer contributions? My guess is they are just not set up for this since the Recordkeepers are doing it.

Had a plan where they could not produce census data for 2023 due to a change in payroll systems. Therefore we were not able to do the SSA. I see the penalties are now "bankrupt an organization" stupid. Anyone have a real world experience? I can see that you can ask for a waiver if the lateness is for reasonable cause. It's a larger plan so this is a good sized potential penalty we are talking about. Can you claim the waiver in advance or do you have to wait for the penalty to be assessed and then ask for a waiver? Curious if anyone has a real world experience... I assume since there is no late filer program they would be pretty accomodating. https://www.irs.gov/retirement-plans/penalties-related-to-the-filing-of-forms-8955-ssa Also wondering if they even send out a penalty when you file late. Hard to imagine getting a $30,000 fine for filing this late. I could see if it was never filed, etc. Anyway look forward to hearing from you!