masteff

You're not quoting the rule correctly. From 1.409(a)-5 Q&A-5: "(1) If the employee has a designated beneficiary as of the date determined under A-4 of § 1.401(a)(9)-4, the longer of— (i) The remaining life expectancy of the employee's designated beneficiary determined in accordance with paragraph ©(1) or (2) of this A-5; and (ii) The remaining life expectancy of the employee determined in accordance with paragraph ©(3) of this A-5;" See also page 33 of IRS Pub 590 http://www.irs.gov/pub/irs-pdf/p590.pdf

As I stated, answer was mainly based on my one experience. Apparently we fell under ERISA Reg. § 2510.3-1©(2)). Thanks for providing the cite.

How is the printing on the back of the certificate not a binding contract?

Pre-reform, on-site medical clinics were entirely outside of the group health plan (we had one at the major oil refining company I worked at for 8 years in benefits admin). I'm not aware of the reform bringing them under group health plans but I honestly haven't done indepth study of the reform. The best people to answer your liability question is your current general liability provider. They'll know what they cover and whether you'd have a hole.

For this purpose, a rollover is not a transfer, and specifically not a 414(l) tranfer. Don't overthink it.

http://benefitslink.com/boards/index.php?showtopic=49517 Fortunately, ERISA preempts stupid attorneys.

I was mildly surprised to see that the article Tom cited says yes.

Kudos to Tom on the finding that article. In some part, I stand corrected (but only by virtue of it being covered by PLRs).

I noticed months if not years ago that views didn't work correctly. Most noticable when you have a thread w/ zero views but several replies.

After further thought, the charity and life insurance part of this is a red herring. The question is: can a self-directed IRA loan money to an unrelated entity? Probably yes, subject to structuring the transaction correctly. Also note the word unrelated; if you're on the board or serve in too close of a capacity w/ the charity then you may start having issues. 1) Does the charity have to pay my plan on-going interest? My non-expert opinion is: yes, they should pay both principal and interest at a commercially reasonable rate. But obtain legal advice. 2) Can the charity provide a balloon interest payment upon receipt of death benefits? My non-expert opinion is: no, it's not commerically reasonable to permit a balloon payment for either principal or interest when it's an unsecured loan. But obtain legal advice. 3) Can my IRA receive a portion of the death benefit (e.g., 2 million dollar death benefit....can my IRA upon my death receive, as an example, $700,000 with the remaining $1.3 million going to the charity? My non-expert opinion is: no, the insurance is outside of your transaction w/ the charity. The charity can payoff the loan w/ the insurance proceeds (a lump sum payoff w/out penalty is commercially reasonable). But obtain legal advice. 4) Is this legal? It appears that it is, but my CPA is not familiar with this type of arrangement. Again, the charity and life insurance parts of this are a red herring. You need to research making loans out of a self-directed IRA... and obtain legal advice. Nothing on this forum should be construed as legal advice... especially not mine. Of course, you could just put $500K into a separate IRA account and work w/ the IRA holder to craft a beneficiary designation that balances giving to the charity and to your beneficiaries. Perhaps: $500K plus 1/2 of any excess to Charity A with the remainder to Beneficiaries B, C or D. (And this is doubly good because you can always change the designation if things go sour w/ the charity.)

This is the ultimate "what does your plan say" question. Of course, MRDs are a form of payment so he is technically in payment if that makes a difference in how you read your plan. Generally speaking, if the plan allows to defer payment to a later time (but not later than MRD) then he can leave it in the plan.

Since the charity proposed the idea, they had to have gotten it from somewhere. Have you asked them for more info? Ultimately on this potentially complex of a question, you should get proper legal advice from a known attorney and not from an internet forum.

Also see 1.417(e)-1: "Also, for purposes of section 72(t)(2)(A)(iv), a distribution that would otherwise be one of a series of substantially equal periodic payments will be treated as one of a series of substantially equal periodic payments notwithstanding the distribution of a make-up payment provided for in paragraph (b)(3)(iv)(B) of this section." Which is about as an emphatic of a "not rollover eligible" as the Treasury department can get.

To expand on K2's answer slightly... You need to separate two events: contribution and investment. Just because you contribute the money into your Roth IRA on 1/1/13 doesn't mean you have to invest it all immediately. You could put it into a money market fund and then do dollar cost averaging as K2 notes. Of course, as he also notes, it's impossible to predict which way will be optimal. While it might be suboptimal, generally speaking doing something is better than doing nothing.

More specifically, page 66.

A payment like this occurs outside the health plan, therefore it's governed more by HR law than it by benefits law. This is mainly a benefits forum. Has she tried simply talking to the office manager? A simple question like "why have I never received that stipend in my 4 years here?" might be a starting place.

You should also ask for anything detailing fees if they are not fully listed in the SPD. Figure out why you had the fees and whether you have any action available to avoid those fees in the future (such as moving to a different investment option, etc). http://www.dol.gov/ebsa/publications/401k_employee.html

Generally speaking about continuing education, it's done all the time. Most common example I've personally experienced is programs that target both CPAs and attorneys; I knew several people who'd use them to "kill two birds w/ one stone". Biggest issue is that different bodies may count hours of credit differently.

Almost can't believe it's for real... but hard to not laugh by the end of it

It took me a bit to figure out where they hid some of the details.... their terms of use do address some of these questions: https://www.savernation.org/o/terms-of-use/savernation-32

I find it telling that searches on the ASPPA and the APA websites find zero results on savernation despite individuals from both groups being listed on the savernation website http://www.asppa.org/sp/Search.aspx?SearchPhrase=savernation http://www.americanpayroll.org/search-result/?q=savernation

I'd say yes, but the participant can opt out.

They've simply duplicated UPromise which puts the savings towards 529 plans or GoodSearch which puts the savings toward charitable causes (or several dozen other sites like them). All they're doing is using affiliate shopping codes to get money back from websites. They pocket some of it and give the shopper the rest. IMO, it's just another marketing gimmick for payroll companies. I seriously wonder how much they paid for the use of the "big names".

May be cheaper than you think: https://www.askebsa.dol.gov/dfvcepay/calculate

You're the plan administrator. It's ultimately your data, not the TPAs. Instruct them on how to clean up the entry dates. Don't be surprised if they ask for it in writing or ask you to provide what you want the dates to be corrected to. (I personally would just determine the correct dates and send them in a spreadsheet to the TPA w/ instructions to update their records.) However I would be curious to hear any thoughts from any TPAs on the topic.