austin3515

I just think they need a carve out, even for plans with less than 20 participants with balances.

WE have a ton of plans on Fidelity's small non-prototype platform. But guess what? There is nowhere for them to go. Well, that is other than an insurance product with expenses of 2%+. Or I'm sure the employer would be happy to spend the $750 out of pocket for RK Direct (a sweet platform of course, but out of pocket is bad...).

Absolutely! But honestly some of these new requests are ridiculous. I'm not opposed to change. I'm opposed to regulators who possess not the ability to view the world from a vantage point of practicality and reality.

back up now, agreed. Thanks.

Let's see how many sponsors just say "you know what, never mind. I'll just terminate this thing." Tell ya one thing, I am all over pooled plans now... They are regulating these participant directed plans to the grave, literally...

http://us.practicallaw.com/w-002-7791 Well this sucks... New Information for Retirement Plans The proposed regulations would also add new questions to the Form 5500, Form 5500-SF, and Schedule R on participation, contributions, and asset allocation by age, and participant-level diversification. Questions include the number of participants: •Making catch-up contributions. •Investing in default investment options. •Maximizing the employer match. •Deferring compensation. •With account balances as of the beginning of the plan year. •That terminated employment during the plan year that had their entire account balance distributed.

Not one of my clients wants to part with $12,000 unless they have to.

Anyone having the same problem?

I nominate Tom! Sell it on Audible!

I have to say Tom, once they let that cat out of the bag it would seem to me there would be a clamoring to get that effective 1/1/2017. OF all the changes, this seems to be the one that would be limited to changing 5 or 6 words in the instructions. No new technology, no revisions whatever to the form itself. Instant relief. I hope ASPPA pounces on this!!

Any word on when this would be effective?

WOW... WOW... This is HUGE.

That was on page 772

That's a fascinating question actually. It seems to me it is an individual protection though and not to non-human enterprises. But then again I do not include J.D. in my listing of credentials and rightly so! "No person shall be held to answer for a capital, or otherwise infamous crime, unless on a presentment or indictment of a grand jury, except in cases arising in the land or naval forces, or in the militia, when in actual service in time of war or public danger; nor shall any person be subject for the same offense to be twice put in jeopardy of life or limb; nor shall be compelled in any criminal case to be a witness against himself, nor be deprived of life, liberty, or property, without due process of law; nor shall private property be taken for public use, without just compensation."

Oh. My. God.

Oh. My. God. You have to guess how many pages it is before you actually open It. It will be more fun that way! https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-14893.pdf

you meant the POST was old, and Regs are new! I didn;t realize the new proposed regs addressed this!

Thanks! Where can I get the proposed regs (other than your post ) Really, thanks! Do you agree that a match of more than 25% would satisfy? They wou;dn't get the match but for the deferral.

Can someone point me to a good write up of when you can send statemetns electronically? We work with a recordkeeper who we converted a bunch of plans too. New recordkeeper essentially has no email addresses. But yet they do not send statements. Instead they say we deliver them electronically. To me this sounds way off-base and I would love to point to some DOL document that clarifies that this does not work.

hey we can both respond however we choose! This a democratic society!

What does counting hours have to do with the question?

Pet peeve: Someone asks if something can be done or how to treat something and it gets side tracked into "why does the client want to do such a thing anyway"? If I wanted to know WHY a client wanted to do something, I wouldn't ask you all - I would ask the client! Laughing as I'm typing but had to vent...

Well, all taxable fringes are subject to OASDI so I'm not sure I get your logic?

Option 4 of course would have been to prove beyond any doubt that they were wrong. I was hoping this maybe addressed at an IRS QA or something. The problem is, it is not a ridiculous position. IT might be widely accepted by us pension geeks as not ok, but to an ordinary intelligent person, it's a benefit just like anything else - they're getting paid for NOT working. Sounds like a benefit. Again, I disagree with the position, but it's always harder to dispossess people of positions and interpretations that are grounded in sound logic!

I have a client who is trying to argue with me that vacation is a taxable fringe benefit and thus not eligible for contributions based on their plan provisions (which do exclude taxable fringe). I know it's ridiculous but its hard to point to something concrete...