Miles Leech

Unfortunately not. The firm I'm with is a relatively small firm that went from a branch of a messy, union-owned insurance company to the management of a sole practitioner who took over when the insurance company went under in 2013, and only in the last few years has it grown to the point we're out now where we have a small team of staff. Much of my role at the company revolves around tightening up policies and addressing edge-case things like this to prepare us to grow & follow best practices, as it's much easier to establish that when small than it is to clean up a large company with piles of issues. I'll speak to my team about addressing document retention in our service agreement. On the security issue side of things, it's not the largest concern as of yet; the records sit in locked filing cabinets inside a locked Records & Server room, which only the owner and myself have a key to. Regardless of retention length we're thinking of digitizing everything we can partially for security purposes anyway.

Thank you, will do some reading on this.

We run a small TPA Recordkeeping firm. While we've moved most things to electronic forms, we still have filing cabinets full of various old documents. The biggest one is distribution request forms mailed to us from participants, as well as inactive signed plan documents back when we handled those on paper. How long do documents like these need to be retained, or is it indefinite?

You do make a good point... most of what I've heard on Roth ER contributions was that they were mostly treated as if a Roth conversion was elected for them as the contribution was made, so outcome-wise it's not a huge difference. I'll likely speak to the client on that this week, Thanks!

One of our sponsors of a solo 401(k) & PS Plan reached out to me today asking about doing their profit sharing as Roth for the 2026 plan year. I know loosely that Roth employer is possible now under Secure 2.0, but we haven't looked into it much at our firm; it's not something we're planning on advising many employers to do given the added complexity & just isn't something we need to deal with much at our size. I have a few quick questions on how I should handle this: Is this something they are allowed to do for solo plan profit sharing contributions (assuming the needed amendment is made), or am I missing something? How should I handle talking about this to them, scope-of-practice wise? I can't attest too much to the tax implications of Roth employer, especially in a solo plan. As a TPA/recordkeeper, my gut tells me it's wise to define my scope as being able to tell them what kind of contributions they are allowed to make & how much, as well as processing them, however determining how Roth employer would affect plan compensation (especially as a solo plan), taxes, and any other implications are outside our scope and should be discussed with a CPA. Is this the right place to draw a line, or do I need to spend some time diving into the details of Roth employer & speak to the implications of it?

CuseFan is correct here, that's my mistake. I directly referenced the definition of wages under §3401 (which normally does include severance payments), forgetting §415 carves out exclusions & modifications. Been a long day, rookie mistake on my part; editing my original response now. Thanks for catching that!

You are correct, terminated employees do not need a top heavy contribution, provided their termination date is before the end of the plan year for the year in question. Under §415, which to my knowledge is required to be used for top heavy minimums, severance pay is not included in compensation.

The two answer above by Pam & Bri are both good places to look. Unfortunately, Relius is a very complex beast & I feel your pain on the highly unhelpful error messages; it's one of the biggest reasons my firm is moving away from Relius this year. In regards to Bri's answer, if you go to plan specs > source summary and click the magic hat button (thanks for the clear labeling FIS), you can generate accounts. By selecting all sources & all investments, you can make sure your plan has an account for every investment-source pair. If your plan has certain more complex provisions relating to source-specific investments, just be careful using this tool. Per Pam's answer, make sure this is done for any relevant plan years. Hope this helps!

"Trailing" post-severance compensation that meets the 2 1/2 month rule is included. Other forms of post-severance compensation (unused leave cashouts, certain nonqualified deferred compensation, salary continuation for disabled participants or military members, etc.) are all governed by the plan document, so you'll have to refer to your specific plan. Our plan documents made through ASC default to include post-severance compensation, with the ability to exclude the various types above. Not legal advice, YMMV

I doubt it. Not a CPA, but I can think of very little advantage to what you describe. If it happens YoY, they're really just kicking taxes down in a cascading way, not gaining much of an advantage. In fact, they're likely losing out. I don't know how much a safe harbor contribution would cost them, or how much of it would go to HCEs / owners, but the tax savings of a) the safe harbor allocation itself and b) the fact that HCEs could defer another $15,000 (or more) combined annually means they're likely losing a pretty significant tax advantage by not doing safe harbor. I do plan design & work with sponsors fairly often, and honestly there's just always some that will refuse to design a plan in the way that makes sense. Some don't want to be safe harbor because they see employer contributions as "giving money away" and they don't want to do that, even when you break down the numbers of how it actually saves them money overall. Some also just simply don't like being told what to do or what their plan should be. I've had prospects come to us who would benefit significantly by being a SH Non-elective instead of their current safe harbor match; they do new comparability profit sharing every year and have to make a full 5% gateway contribution on top of their safe harbor. Non-elective would save a huge chunk of money for a company that wants to max out its owners, but they came looking to offer match and are set on sticking with it.

Treas. Reg. §1.410(a)-7(a)(3)(ii): Employment commencement date reads While 1.410(a)-7 is, in general, about the elapsed time method in particular, this section states "in order to credit service accurately under any service crediting method". Unless there's precedent out there otherwise, I would assume using the date they actually started working would be defensible under the above definitions, as they never worked an hour of service prior to that. YMMV, Not legal advice, etc etc.

Are you saying the plan uses a permitted disparity formula and is using 100% of the taxable wage base? If so, you could view the formula as either 6% of all compensation, plus an additional 5.7% on any compensation over the SS wage base 6% of compensation between 0 and the SS wage base, and 11.7% on compensation over the integration level Both achieve the same thing, and I've seen different individuals prefer calculating it either way. If you're asking specifically about a formula for excel to calculate it, I'd use =0.06*B2 + 0.057*MAX(0,B2-176100) Assumes 2025 taxable wage base, replace the 176,100 if using a different year. B2 would be the compensation used for allocations, can be changed to meet your needs.

Had a similar shock entering into my firm, which uses FIS Relius for recordkeeping + compliance. As someone on the younger side (especially for this industry) and with a lot of exposure to modern tech, this industry is decades behind. That said, there are some pretty good options emerging. Congruent's CORE recordkeeping platform has blown us away with actually looking & feeling like a modern cloud-based system that is still highly functional. Definitely worth getting a demo & looking into. At RANDUG this year, along with Core, there's a platform called Penelope that seemed fairly intriguing. There's also SS&C, Schwab's RK tech, and I feel like ASC has a RK platform as well, but don't quote me on that. On the documents side of things, ASC's documents are far superior to FTW in my experience. The user interface & process of designing plans is so much smoother, and they have an API system for integration with any proprietary firm software you may use. These are the only two vendors I'm aware of in the Doc space, but frankly ASC is so easy to use I don't have much of a drive to look at alternatives. For compliance, it's once again really just ASC and FTW I'm aware of. I'm not thrilled with either compliance module, and this is the area the industry needs work. Because of this, I'm actually in the process of designing & developing a modernized compliance testing software with a friend of mine. It'll be a good year or two at least before it's ready but it's coming along well.

This is very helpful, thank you!

Our firm pretty much exclusively has done small / micro plans (90% of our plans are <1M in assets and under 30 participants). As we grow, I know large plans are likely something we'll have to deal with eventually. We have one plan that's getting close enough to the threshold for requiring a large plan audit that we know we need to start thinking about that in the next few years. With our plan demographic, we've never once actually had a large plan audit. What kind of things should we expect? Does the auditing firm just ask us for a bunch of reports, and if so, what kind of information is generally requested? In the case that anything out of place is found, how much leeway is there in terms of them talking to us about correcting it vs reporting failures on an audit? I'd hate for a large plan audit to be the way we find out we're operating something wrong & cause problems for a client. Any guidance as we start to move into plans that may require audits?