DLavigne

It's true that only participant-directed monies need quarterly statements, but Sal Tripodi replied to a Q&A in the PPA webcast specifically about plans that have both participant and trustee-directed monies. The reply was that both need to be reported on the quarterly statement, but only as of the most recent valuation for the pooled portion. That's why it seems silly to me to duplicate information the participant has already received (either on the quarterly investment statement or the annual statement from us). I spoke with my boss this morning about the issue and we've decided to take the language in the law literally. If the investment company provides quarterly statements on the participant-directed and we provide annual statements for the pooled, then we're not going to give quarterly statements on the pooled. The regulation says annual for trustee-directed, so that's what we're going with. We also decided that if an investment company does not provide the investment language that's now required, we will send out a one-page supplement with only the investment language that the employer can hand out each quarter to the participants. If more guidance comes out about this, then we may change our ways of course.

This question is a little off the original topic, but what about plans that have some participant-directed accounts and some trustee-directed? On the participant-directed side, they receive quarterly statements directly from the investment company but they only get an update on the trustee-directed (pooled) account once a year when we do an annual valuation. Do we really have to start providing quarterly statements just to give them a value of their trustee-directed piece? I remember hearing that the trustee-directed monies only have to be valued annually, so our new quarterly statement would carry the same value until the next annual update. It seems ridiculous to me that we would need to do that. We would have to increase our fee to provide quarterly statements and the quarterly statements really wouldn't tell them anything they don't already know. I'd like to contact the employers affected by this to advise them of the law change and the increase in fees, but I'm not sure who it really affects at this point. Thanks.

Thanks for your reply. In this case, Small is no longer the employer - the company was sold to Big. How does that change your response?

Hello. We have a situation I haven't experienced before and need some assistance. A small company that has a 401(k) we administer (I'll call it Small Co., since I'm not very creative) was recently purchased by another company (Big Co.) that is a member of a PEO. Big is part of the PEO's 401(k) plan and tells us that the employees of Small cannot participate in it. 1. Can the existing Small 401(k) be amended so that Big Co. becomes the plan sponsor and the plan will continue to cover just the Small employees? 2. Can it be run and maintained separately, or is it similar to a controlled group situation in that the PEO's plan and the plan maintained for the Small employees must be tested together? 3. Is there anything else I should know about this situation? Thanks a lot. I hope never to have to deal with PEO's again after this!

We have a plan that had a participating employer using the plan. The participating employer decided to discontinue participation in the sponsoring employer's plan and start up its own plan. The document says that this is permitted. It also states, "The Trustee shall thereafter transfer, deliver and assign Contracts and other Trust Fund assets allocable to the Participants of such Participating Employer to such new trustee or custodian as shall have been designated by such Participating Employer, in the event that it has established a separate qualified retirement plan ..." Does anyone know if that means the vested account balance of those participants or is it their entire account? If it's the vested balance, then it's treated as a rollover into the new plan? If it's the entire balance, then it's subject to the new plan's vesting schedule or the old plan's? Thanks!

Our company is new to Relius and although I've seen some messages posted about a contributions report broken down by participant, I have another question on the issue. We had a wonderful report in Blaze SSI that listed by participant compensation, deferrals, deferral rate (as a percentage of their comp), match, match rate, safe harbor 3%, profit sharing, profit sharing rate and then total contributions and total contributions as a percentage of comp. This was a great report to check deduction limits, 415 limits, the 3% SH calculation and comparability percentages. Relius is having a difficult time coming up with something similar and we feel it will be very difficult to live without that report. Does anyone have anything that's similar that they would be willing to share? Another report we're having a hard time getting is just a 1-2 page summary of plan provisions report. In Relius, you have to print off a page for each type of plan spec, but I'd like something that summarizes the highlights on 1 or 2 pages. Thanks.