msmith

We report Commissions and Revenue Sharing (if any) on the Schedule A. Any fees paid for distributions and loans are reported on Schedule C. Schedule C is also used to report any Plan paid expenses (to TPA or CPA Audit fees). Janice Wegesin has had multiple webcasts regarding the completion of Schedule A and C, with great examples. If you have John Hancock access, you can review the webcasts on their website.

What is everyone using for the PPA restatement effective date? Are you going back to the original effective date because there was no IRS reliance on the prior document? Any comments are appreciated.

Thank you, imchipbrown.

Many thanks to all that replied.

Any comments on how many Plan Years you would carry a receivable Matching contribution (whether or not discretionary)? What about a Money Purchase contribution? Client has been advised to discuss the deduction issue with their CPA and about disqualification.

I believe FIS (Relius) has updated their checklist entries to include the changes. However, as a TPA, we are waiting for final guidance before we contact Clients regarding their preferences.

Another question I have is do they pay back the amount to the participant that received the overpayment? If not, to whom? It seems as though the participant receives a windfall.

We also record as earnings.

I agree with Tom. We use gross compensation for ADP/ACP testing if the 414(s) testing fails.

Thank you, ETA. I could not find anything in 2016-51 about double duty for this purpose.

I have a takeover plan (from a payroll company!) that never corrected the 2016 failed ADP Test and the Plan Sponsor was never told the Plan was top heavy. If correcting the 2016 Plan Year, under SCP, can the QNEC also be used to correct the top heavy minimum allocations (same as the current year use of QNEC to satisfy TH minimums)?

Company started in July 2018. For a calendar year plan, we will have a 01/01/2018 effective date. Do we have to pro-rate the TWB if using imputed disparity to pass the general test?

Thank you, Larry. I thought that was the date - but started thinking too much and thought that was for a Coverage correction.

For a 2017 calendar Plan Year, what is the latest possible date to adopt a corrective amendment to permit early entry for an employee that did not meet eligibility (non-highly compensated)?

I have a few Clients that fund Profit Sharing throughout the Plan Year. However, we always perform a true-up/true-down when we receive the annual census.

Thank you, BFlash!

Is anyone else having difficulties, receiving Schedule C data (direct and/or indirect compensation) from American Funds? If so, how did you resolve?

Is the Office Manager a Union member? Most Taft-Hartley plans I have seen have Office workers that are not in the union.

Thank you, Tom. Yes - Ratio % Test.

Employer has several USA Divisions and there are 3 401(k) Plans: - Plan A by other TPA - Age 21 and 6 months, with monthly entry dates, Safe Harbor Match - Two Plans by us as TPA - Plan B has entry on the date of hire and is a Safe Harbor Match. Plan C has a 2-month wait, with monthly entry dates and discretionary match. Plan C is a smaller Plan and will not pass coverage on its own. However, this Plan was effective 01/01/2017 but they did not hire anyone until mid-November 2017 (i.e. no contributions as no one was eligible). We cannot use the RPT for coverage - correct? If not, I believe we can use the ABT - correct?

You can check the Plan Document. The Document we use has a Slayer statute that states: "The Administrator may apply slayer statutes, or similar rules which prohibit inheritance by a person whom he or she stands to inherit, under applicable state laws without regard to federal pre-emption of such state laws." However, I agree, ERISA Counsel should be sought.

My question related to the gain/loss allocation attributable to the Plan Year (no short Plan Year here, unless all accounts paid out before 12/31/2018. The Plan Document defines "income" as follows: "Income" means the gains or losses for the "applicable computation period" allocable to an "excess amount," which amount shall be determined and allocated, at the discretion of the Administrator, using either of the methods set forth in (a) or (b) below: (a) Method of allocating Income. The Administrator may use any reasonable method for computing the Income allocable to an "excess amount" for the "applicable computation period," provided that the method is used consistently for all Participants and for all corrective distributions under the Plan for the "applicable computation period," and is used by the Plan for allocating earnings to a Participant's "specific account(s)." (b) Alternative method of allocating Income. The Administrator may allocate Income to an "excess amount" for the "applicable computation period" by multiplying the earnings for the "applicable computation period" allocable to the "applicable contributions" taken into account under the test or limitation giving rise to such "excess amount" by a fraction, the numerator of which is the "excess amount" for the Employee for the "applicable computation period," and the denominator of which is the sum of: (1) The "specific account(s)" balance(s) taken into account under the test or limitation giving rise to such "excess amount" as of the beginning of the "applicable computation period," and (2) Any additional amount of such "applicable contributions" made for the "applicable computation period" to the "specific account(s)." (d) For purposes of calculating the Income attributable to Excess Contributions of Section 4.6(b), the terms "applicable computation period", "applicable contributions", "excess amount", and "specific account(s)" will have the following substitutions: (1) The Plan Year shall be substituted for the "applicable computation period"; (2) Elective Deferrals, and other contributions included in determining the ADR under Section 1.9, shall be substituted for "applicable contributions"; (3) Excess Contributions shall be substituted for "excess amount"; (4) The Elective Deferral Account, and, if included in the determination of the ADR under Section 1.9, the Qualified Matching Contribution and/or the Qualified Nonelective Contribution Account(s), shall be substituted for the "specific account(s)."

Calendar Year plan terminating mid-year in 2018. Plan Sponsor is hoping to have all participants paid out before 12/31/2018, to avoid a 2019 5500 filing. However, the Plan has failed the ADP Test for the 2018 Plan Year (from 01/01/2018 to date of termination - business sold). Is it possible to calculate corrective distributions mid-year to avoid the 2019 5500 filing? If so, do I just use the gain/loss to a current date?

We prepare a Contribution Declaration, with an attachment that provides the breakdown of the PS by participant. However, we do not include the Safe Harbor allocation, as there is no discretion with the SH source. Generally, a preliminary spreadsheet is provided to each Client that will detail all Employer contributions allocated for the plan year.

I could not agree more with all of the responses. This is a great forum for discussions/questions from User opinions that I respect (outside of my co-workers opinions).