No Name

We open "Company Retirement Accounts" with a company I'll just refer to as Chuck. There are checkboxes to indicate what type of Plan and Trustee information. With suffient assets ($5k, I believe), you can request a checking feature. I've opened these with the EIN with no problem (20+ years). Now that its easy to get a TIN, I would probably lean that way. There's a Form (W-9, W-8?) to delare exemption from tax reporting. I agree, you have to watch out for institutions that want you to sign a new prototype every time you open a new account. Ever have a client with six Plans (001-006) because of some rookie?

I may be getting old, but seem to recall something about a de-minimus $25,000. Don't recall what it referred to, but may be worth a search.

If its any consulation, it happens a lot. I'll bet they have a runner that brings EZs from one box to the other. There was a year or so when my company didn't even know there were separate PO Boxes. I think they're also still addressing them to PWBA.

SIMPLE terminates after 2004. Case closed.

no. anti-alienation. beef is with the employer.

In addition, check what the loan provisions allow. Some require payroll deduction for repayment.

Sheesh, we're getting old. I remember benefitslink in 1995. Hasn't Dave made great strides since then? There's a URL somewhere that lets you see what a site looked like years ago. Can't remember.. archive something?

Safe Harbor 401(k), within the rules, will not be Top-Heavy (even if it is outside the rules).

As an aside, I've read that the contolled group rules sprang from progressive tax rates. Say 15% up to x, 25% on next y, etc. Some spoilsports decided that they'd set up January Corp, February Corp, etc. Each would bill for their month, and all would be in the lowest bracket. Seems ridiculous, but there you have it.

I think you need to disclose that fees will be charged before actually charging them. Something in the form of a SMM.

Yes. Check the SPD. Most plans I work on vest Plan Years; years in which you work at least 1000 hours. An ugly example may be that you start work August of year one and leave June of year five. In this example, you probably don't get your year 1 vesting (less than 1000 hrs August-December) or year five (less than 1000 hours January - June). Check the service crediting rules. Could be "elapsed time". Also, check the vesting schedule. Sounds like 5-year cliff vesting. I don't work union plans, but I think they may be subject to more permissive (less good for you) vesting schedules.

As I understand these animals, you calculate a benefit under a formula, then the insurance company calculates a commission and a premium for you. Your job is to smile at the client and tell them what a good deal they're getting. Nice work if you can get it.

Any weight that can be added to a filing is welcome. I've been vexed that the Schedule R has been useless in most cases. Zero on line 1, make 3 copies. Schedule T at least had some purpose. Dis-heartening.... :angry:

Such a muddy little creek! IC status should be explored first; dirtiest of the problems. Loan policy could be changed; usually a document separate from the plan. Maybe IC's could be allowed repayment priveleges. Good for the spouse. I wouldn't allow deferrals until IC issue resolved. Might even insist on a form declaring "0% deferrals" while issue 1 is resolved. Issue 2 is also tricky. Is there a separation from service, or a hat change? I've taken so much time to write this that I'm afraid someone might get ahead of me, so hitting send.

Here I am. Send me a check. How much was that anyway?

As an aside, I have a plan where the participant quit. Got paid out. Six months later, Dr. begs her to return to fill in. Works > 500 hrs and gets more $. Quits again, paid again. Begs again, returns, but this time works less than 500 hours. Whew. Tough finding good people.

In fiscal year situations, sometimes the "offending" deferral hits the account sometime later than the end of the year.

WDIK, Blinkey, mbozek. You answer a lot of questions. I'm sitting here with six-eight billable cases and have spent nearly two hours on this board. Is there a Benefitslink Anonymous chapter in Northern California? I think Mike Preston might have found it.

How do you suppose this would be audited down the road? I'd print out a daily val report on signature date, grant the loan, and sleep all night. Even if the holdings were Worldcom and Enron. Unless you have foresight on the market, who knows what will happen tomorrow?

Harder to get re-employed with Death, 2004-2005, on your resume. Believe me, I know.

Thanks, Appleby Let's keep this balloon off the ground. I bought Derrin's "Who's the Employer" several years ago. I've since left the company, so the book remains there. I believe he had a small section addressing shared premises and what was a "business" vs what was simply a bank account, which may be relevant. May have to re-buy that book someday.

There may be other records, such as health plan dependents, etc.

Here comes a cavalier suggestion certain to cause an uproar. How about opening up a new Company account (ABC Forfeiture on account of Joe(sefine) Blow), transfer in your $65k. Taxes on interest paid from this account. Money is out of the plan.

The "MAY" provision is in Datair (IRS approved) documents. I find most small plan sponsors send out termination paperwork and if they receive no reply, do nothing. Just finishing up a plan that had a mass departure of employees in 1996. There are 3 active participants and 19 individual accounts.

More pages looks more important. We charge by the pound