austin3515

Mojo, your assumptions are correct.

Calendar year plan requires employment on last day of the plan year. The employee works on December 30, 2016--a Friday. Was the Participant actively employed on the last day of the plan year? Seems we can go either way with this one...

Yes, nongovernmental. Classic federal governemtn to who have 2 plans nothing alike defined in the same code :)

Which provider?

Another wrinkle: Let's say the plan is a pay-period match, and bonus is run as a separate payroll. Now what?? Amendign to include bonus does nothing for a pay-period match in this scenario because no 401k is withheld (i.e., because bonuses were excluded for everything).

i.e., in one brokerage account, with the allocation of gains made once a year at plan year-end, correct?

I can't think of any reason not to commingle a 457b and 457f investments? OK, there are different vesting rules, but it's no different than a 401k FBO account with PS and 401k. Let me know what others are doing. Also, it would be one single Rabbi Trust for both plans.

And I let them in early, so they are otherwise excludable, but that is a very good point.

So you've actually done that before then? I want to make sure I'm not a trailblazer!

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.