Bird

Unfortunately sliding the price down does not necessarily trigger buyers in any kind of uniform manner. If someone is not willing to pay 60 cents on the dollar then the dollar is probably overvalued. Not sure what to say that is actually helpful here. For anyone reading this, it is another poster child for not having real estate in a qualified plan.

I think the best answer is "as long as it takes to be able to prove that someone is getting or got the right benefit." IOW forever.

Wow, couldn't be much clearer.

Tom, OP said a 1099 was issued. If you did indeed only miss one payment, then almost certainly the the loan should not have been defaulted and the 1099 was issued in error. There are a few possibilities, all of them to do with incompetence. Could have been your payroll department didn't restart the actual deposits, or deposited to the wrong person or who knows what. Just be prepared for a long slog through the bureaucracy and don't give in if you are sure you are right. Unfortunately we do get some posts from participants who are convinced that something happened when it really didn't, so be 100% sure your paystubs are showing the loan payments. First step is comparing them to your 401(k) account statements.

I assumed calendar year since it was started Jan 1 but that is a good question!

So you want to change to a formula that doesn't satisfy the general test but would satisfy a design-based safe harbor? I'd say no, but that's just a gut reaction. I imagine there is no cite saying you can do it, just an interpretation that says nothing prevents you, but I'd be uncomfortable trying to sell it to an auditor. (How bad could a pro-rata allocation be vs integrated?)

That's my point. The ones selling these blurt out "DOL" like...everyone knows they are evaluating fund lineups or something.

Without looking anything up, I think that is fine. I think the only requirement is that the plans themselves don't overlap.

Is it just me or is this the most over-hyped "thing" in the last 5 to 10 years? I can't have a conversation with a recordkeeper or advisor without someone blurting out "3(21) and 3(38)" (and usually having no idea what they are saying). It seems that any real protection is from participant lawsuits - in the small plan market, that is simply not a threat. Is the DOL going after anyone for having "bad" investments? And...I know these services are inexpensive or "free" but it seems to me that to the extent there are costs, they are borne by the participants, but trustees and advisors are the ones being protected. How wrong is that?!

Yes, sorry! (fixed)

Just a reminder/clarification that these are effective for plan years beginning after 12/31/18.

I don't think so (hope not because our authorizations don't use it). I'm pretty good at being very careful about setting things up...and then completely forgetting the details about how/why.

This is correct.

I'm not convinced; I think the language above taken all by itself is misleading - to not elect a life annuity a participant must waive the J&S and get spousal consent.

My understanding is that if a PS plan offers an annuity option, it is subject to QJSA rules, period. As I skimmed that RR, it seemed to cover situations where a plan did not offer annuity options as part of the plan document but certain options were available as investments that provided annuity options. I could be wrong and I'm sure I'll find out quickly enough if so!

Sounds like the "friendly QDRO" concept where you go through a sham divorce or otherwise get a QDRO to let your spouse take your money out of a plan. I thought this was shot down but don't recall for sure.

I think the intent is that you can't make contributions to both plans for the same year. I wouldn't try to stretch that by, say, alternating contributions from year to year, but I would not be concerned if the SEP existed in 2018 with no contributions actually made for 2018.

Prior years' deposits/history don't matter. You have to file when assets exceed $250K, period.

Ft. William did theirs in April 2017

Fort William has a new notice out.

I say yes. The insurance policy is, or should be, split between sources.

No problem. Insurance is in essence a self-directed account and unless there were weird restrictions put in place you could use any source.

You are essentially doing the general test in your head. Don't be a slave to your software and its limitations.

... wouldn't worry about it too much; just document it thoroughly in case it comes up later. (Send it in and let the institution code it as 2018 if they insist.)

I agree. If you were to match up the amortization schedule with the actual payments, they would all be on time. But...QDROphile makes a good point. There is a distinction between a "pre"payment and "extra" payment. If you wind up reducing the total amount of interest paid because of these payments, then they should probably be treated at "extra" payments and that means subsequent regular payments were missed and the loan defaulted. I'm not sure I would take it to that level but I do believe that is correct.