austin3515

3. Definitely yes. Of course ask, because never assume. But I already know the answer you will get. Best case scenario is new money goes to new vendor and you can politely ask the people at TIAA to transfer their money to your new platform. And good luck with that. Our experience is teachers view TIAA-CREF as the benefit itself. Our clients are extremely frustrated with them but the participants never want to go. Now granted, most of my clients are less than $50MM in assets. I have on in the 80 or 90 range, and there is a different level of service up there. I'm sure if you get into the billions they'll set up an office at your school :).

Appendix B, Section 2.07(3). It says you can limit the corrective amendment just to those who actually made contributions improperly. Instead of developing some convoluted system of identifying the "one" person (an NHCE) can we just name their name?

I definitely believe you, I was just curious what would need additional funding since it's already there. Probably they don't even have enough people to keep up with day-to-day let alone implement a change. I've been in those situations before for sure...

What do you mean by this? I guess I can see where reprogramming the entire form would be a very costly endeavor, but why so for the compliance questions already there?

Ha, I have a couple of slides on the new 5500 coming down the pike, and my last point is "will this ever happen??" For example it seems hard to imagine Trump forcing every small health insurance plan to file a 5500. That policy seems, well, dumb. Really really dumb.

No way, not in this case.

Putting together a training with an IRS/5500 update. Any word on the status of the Compliance questions? I know they are n/a for 2016, I'm just wondering if there is anything published about when perhaps they might be effective. Any official guidance, etc.?

You know, it really was just an unwillingness to acknowledge that ____happens, and a further refusal to take into account that "hey, this must be a good guy/plan sponsor if they're voluntarily coming in to the program." My impression was really "you better watch what you say and how you say it--you're dealing with an investigator, and this is an investigation." Even though this was not a big deal, this in their eyes was actually a very very serious matter.

late deposits. One of them was for a miniscule amount of late deposits for which we were "asked" to file. The fact that the dollar amounts were miniscule is of absolutely no concern to them.

I will never do it again unless I absolutely have to. It has been excruciating. I have been through 2 of them now and each has been extremely difficult.

Assuming the OP means what we all think of as "interns" (half of us probably had internships for crying out loud) and not a rouse to impose an undue wait time, then I say keep it simple and exclude interns as a class.

Thank you for mentioning this, I was aware of this issue.

Yeah, I am going to have disagree with you on that point.

Company A does not want to pay you $500 an hour (or me $15 an hour :)) to dig up documents for the last 12 years that the IRS might be asking for under audit. Needless to say both of us deserve to be paid for the value we bring to the table! Were those ADP refunds paid 5 years ago? How that top-heavy calculation for 2014? Was it done right? Company A has a lot of widgets to make and would rather use all that due-diligence expense to pay off the seller!

My clients almost across the board want what is best for them in these situations. And I can't say I blame them since the Employer presumably is giving them a nice benefit going forward, and they are not taking anything away from the employees - who by the way can roll their money over to the acquirer's plan if they choose. Now listen, if I was talking to a national business of course I would walk through all of the options. But company A with 50 people buys Company B with 10, I'm terminating B's plan every day of the week (and would explain why A would be "crazy" to agree to assume any past transgressions that B might have committed unkowingly)...

Not for me. We terminate the day before the sale always and terminate. Who wants to mess around with protected benefits and different vesting schedules and plans with 15 sources. just a mess. BUT in the original post, this is NOT an option. There is NO change in Employer taking place in the original question.

yes

All hired in 2016. So should work for 2017 and 2018. By 2019 they will be eligible for the SEP. May not be worth it to save the 2%, but at least it's an option...

Owner has 5 years of service and the only eligible employees have just 2. Owner sponsors a Safe Harbor 401k providing the top-heavy minimum 3% as a SHNEC. Can he maximize his 401k in the 401k plan for 2017, and contribute the max to his SEP account for 2017 but not give any additional contributions to the employees (because they are not SEP Eligible) (i.e., in lieu of bumping them up to the gateway minimum). My research tells me yes indeed this works, but please let me know your thoughts!

Did you already get your opinion letter? Still waiting on mine...

I have to tell you I was blown away at how beautifully the mapping worked by Corbel. We checked, believe me (and I know that was your point, that not everyone checks), but it simply never happened where something like this was an issue during this process. I often quote Reagan - "trust, but verify." Now I saw another provider who switched documents during PPA who for example did not exclude HCE's from the Safe Harbor Match. Talk about the doo-doo hitting the fan... Btu also a great example of what I mean. It simply never would have happened without switching document providers--the two are inextricably linked.

jpod took the words right of my mouth. Smart-money is on explanation 1.

TPA needs to make sure their malpractice policy is up to date . Out of curiosity, take a look at the document before the PPA restatement. Sometimes TPA's switch document providers and as a result the conversion process is hyper-manual and therefore prone to error (such as the error of failing to check the box permitting Roth 401k). That's not a correction, but should make the VCP a slam dunk.

Such a cynic

Or you can get 2,857% of that return by investing in the KGPF