VTPension

For the Forf issue, the effective date is the first day of the plan year following the adoption date. So any document adopted in 2015 will have the forf use shut off in 2016

What about an non-calendar year Safe Harbor 401k plan? For example, as July 1 - June 30 plan - could the PPA restatement be done by 4/30/2016 and make if effective 7/1/2016 if we were making any provisional changes that can't be made mid-year, or make it retro to 7/1/15 if there are no changes?

So a QACA that has a QDIA so that it is also an EACA can have the 90 day permissible withdrawal? I have gotten conflisting answers from 2 sources so I am hoping for a tie breaker. thanks

So it has been months since the first post on this topic and you've all probably lost interest in it. But I am now faced with the issue. All the comments make some manner of sense but what about the fact that the employer is getting the deduction for the premiums? Should he/she be able to deduct a pension allocation against wages he didn't pay? Think of a plan that is stuffed up to the 25% limit - should that 3rd party pay really be included? And, if the insurer had reported the income it would not be an issue at all, but just because it was reported by the emplouer even though not paid by the employer it is? I could go either way on it. If a client points on 3rd party sick pay, I'd probably back it out. If it was there and I didn''t know it, I probably wouldn't care. So now I wonder if we should be asking for it to be broken out in our annual data requests.

I'm comfrtable with the process of making the corrections, I'm just curious if you are all reporting EACH AND EVERY LITTLE LATE DEPOSIT, even if the amounts involved are tiny - for instance, less than $10 in interest penalties.

I wonder if any one out there is using any sort of minimum amount to report or not report. For example, we have a client who was late on one $1300 deposit during the plan year - all others were one time. The $1300 deposit was 5 days late - at 8% interest, the additional deposit is $1.42 and the 15% excise tax is $0.21. It is now costing the sponser mor to fix the problem than the problem itself. Is there any guidance out there for this?