WDIK

Aren't Schedule B's for defined benefit plans?

If the discretionary match amount is specified in the SPD, a SMM would be required. As already pointed out, it is simply good policy to make participants aware of changes to the match formula as many make their deferral decisions based on that information.

Since there is already hypothetical litigation, I would recommend retaining hypothetical legal counsel.

How, hypothetically speaking, did the hypothetical TPA reconcile the hypothetical assets to the hypothetical account balances that hypothetically include the hypothetical participant that was hypothetically paid out twice?

This thread and other related threads in the "IRAs and Roth IRAs" forum give additional useful information.

Good Thread

I deal almost exclusively with small plans where the owner of the employer adopting the plan is also the Trustee, so fiduciary status is already established. There have been some interesting discussions on these message boards regarding employers and the functional definition of fiduciary.

I don't know if this applies to your situation, but church plans not electing coverage under Code Section 410(d) are not required to file Form 5500

In my opinion this will not cause any problem if the sponsor's EIN is the one that was or would have been used on Form 1099-R. I would not amend prior Schedules P but would start using the trust ID number once it is assigned.

Thank you.

At the risk of looking foolish, this will probably fall under the category of "New Things I Learned Today," but I am a little confused. The defined benefit prototype plan document that we use has the following language concerning actuarial equivalence and lump sum payments: "...for purposes of determining the amount of a distribution payable [in the form of a lump sum], if it produces a greater benefit then Actuarial Equivalence will be determined on the basis of the applicable mortality table and applicable interest rate..." (Emphasis added) Please excuse my lack of understanding, but any clarification offered would be greatly appreciated.

I don't read code "7-Normal Distribution" as having anything to do with Normal Retirement Age under the terms of the plan.

EDSAADE: Are you referring to the requirement under 411(a)(10)(B) calling for certain participants to be allowed to elect to stay under the plan's old vesting schedule? (Edit for grammer)

Does having twelve questions in a single post set any records?

I was going to try and post a copy of a letter to the PBGC and their response to show a precedent, but Blinky's word probably carries more weight here anyway.

I think that Blinky is right on point. I have dealt with similar situations and have received both written and verbal verification from the PBGC indicating that such a plan is not covered under Title IV because "substantial owners" are the only employees.

Some clothes are apparently registered Medical Devices. See this site as an example.

Yes. In fact, if you don't show zero participants you will receive a letter noting the discrepancy between the entries.

The instructions for the 2003 W4-P indicate that "Your previously filed Form W4-P will remain in effect if you do not file a form W4-P for 2003."

I found this thread useful.

We don't currently have any target benefit plans, but the prototype document that we used to use required an interest rate between 7.50% and 8.50%.

It is an issue of PTB. (Pass the buck.)

Chris: I thought the same thing initially, but I think that the problem is complicated by the fact that Individual B claims that his identify and SSN were stolen and used by A. Surely the employer could identify which of the two inidividuals showed up to work and earned the paycheck and received plan contributions. The issue of stolen identity would be pursued through other legal means.

Generally speaking, participants are divided into classes based on some designation (ownership, job classification, etc.). Then contributions are allocated to each participant in some manner relating to their compensation within their specific class. The factor of age comes into play as the "conversion" is done to test on benefits rather than on contributions.

This is how I interpreted the other posters' comments.