movedon

Re the vendors' assertions that the business "can't have any employees", one possible reason is that they don't know what they're talking about. Many vendors put these solo 401(k)s in a completely separate department from their normal qualified plans department, and the people therein simply don't know anything about pensions. I have had the same argument with both vendors you mention trying to get them to transfer funds in a takeover situation without processing 1099-Rs, for example.

I agree with the notion that it's not a stretch from a policy or intent standpoint that forfeitures shouldn't fund safe harbor contributions. But I agree even more with notion that it's trivial, and it also seems like one more little unnecessary IRS dig against safe harbor 401(k)s, right along with the position that you can't amend them mid-year even for lots of reasons that are pretty immaterial to the safe harbor nature of the plan. Why do they hate safe harbor 401(k)s?

You can get by without a TIN, but ya' gotta have an EIN.

I claimed I was going to blow this off, but I didn't. I've called the IRS ERPA line about a half dozen times in the last two months. Their responses have varied from "we're going to send you a card soon" to "we sent you a card last week" (each of three different weeks). Last time they told me they sent something on October 1, but I still haven't received it. I renewed in April, IIRC.

I missed this thread before because I don't file 945s, electronically or not, but I will offer an opinion about the ASAPs - I definitely don't notice them now that they are cluttered up in the new email format. For what it's worth, I get so much spam from ASPA these days, and the unsubscribe buttons are so ineffective, I'm thinking about blacklisting ASPA altogether. Not that that is your fault or your problem, but since I'm griping...

Is 1 a percentage of pay? If so, I'd say it's fine. I guess technically if they did both in one year they might have to general test it, but it will pass on a contributions basis.

The solution may be just as simple as arguing your way up the food chain with the vendor until you get someone that knows what they're doing. I had a similar problem (minus the name and EIN change) when trying to move my own solo k plan away from Fidelity a few years ago. I yelled at a progressively more senior chain of supervisors until I finally got the right one. If you're an ASPA member, you can also use the ASPA online yearbook to find someone employed by the vendor that ostensibly knows enough to help.

Thanks for the replies, guys. I decided to test the futility of calling the IRS, and I got pretty much the response I expected - after interacting briefly with a voice response system, a message informed me that they are currently having very heavy call volume regarding my subject of inquiry (I just called the ERPA number and selected the option indicating I don't know anyone's extension), and they cannot take my call right now. Then it said something kind of funny - "please try again on a different day." Then there was a dial tone. I think I'll take Kevin's approach. My payment cleared, and I haven't been notified that I'm off the list, so I think I'll file this away under "resolved" and move on.

I renewed online a couple months ago. Payment cleared, but I've never received anything indicating I'm renewed. Anyone know whether there's typically a response of some kind from the IRS? Thanks.

I noticed today while perusing the new ASPPA website that the yearbook link is missing. I called them to inquire and was informed they are not planning on offering the yearbook anymore - online, in-print, at all. It's still listed on the website as a "member benefit." Boo, ASPPA. Anyone else think you're going to miss the yearbook?

How does the employer engage in "good faith bargaining" with itself?

How is buying a business a hardship, even under facts and circumstances?

3, 2, 1...

You ought to see the deferral election I use for my own solo k - not only is it evergreen, it's covered in little scratch-outs and initials and dates and all sorts of crap written in the margins. The fact that I do it myself as a pension consultant doesn't make it right, but it's pretty funny at least.

Ha, until you call them up and tell the person answering the phone to do something re the assets, and suddenly he/she is a pension expert explaining to you why they can't do what you want... like insisting that you fill out "distribution paperwork for the 1099" when you are just trying to move the plan and transfer the assets to a new provider. Yeah Fido, we know how you do. Woof.

As far as I can tell, the view counts have never worked.

Sorry, I missed this post back in May. Yes, by "controlled group testing" I was referring to a CG with multiple DC plans, needing AB testing, cross-testing, the whole bit. I ended up buying the software anyway and using it to do the testing, and it was fine. It didn't produce a report that said "each plan in the controlled group passes 410(b)," but with a little manual work and playing the system, it's easy enough to get results. Beats testing six companies with 700 employees in Excel. FWIW, I got an email from FTW recently saying the system does now "handle" controlled group testing. They told me they were working on it when I signed up (guess they weren't just selling). I haven't tried it yet. Overall, I like the software a lot - easy to learn and use, and also easy for someone that knows what they're doing (pension-wise, I mean) to override things and make it do what you want without having to jump through a lot of hoops to trick the system (looking at you, Relius). I'm talking strictly about plan specs, census, testing type stuff here and not transactional admin type stuff (which I haven't tried and don't plan on trying ).

This is not working for me today. Anyone else? Hmm, it works if I'm logged in, but not if I'm not. I don't usually do it that way, so I don't know if that's normal.

Whatever it was, it's fixed this morning. Thanks, Dave!

Thanks guys for the replies. You're both right - there are other ways to get there. The "view new posts" way requires you to be logged in (I normally am not). There's also a way to get there by going to the forums main page and then clicking a link at the bottom right to view recent posts. Neither is that big of a deal, just not the way I usually come in.

Still not working for me - when I go to the home page and roll my cursor over the "Discussion" link, the drop down menu no longer contains a link for "latest messages" or whatever it was.

Bueno?

I think that discovering a failure (significant or not) and choosing not to correct it becomes a fraud-ish situation.

Not the first time the person speaking on one of these phone conferences said somthing stupid and wrong.

I think TPAs talking to participants is terrible for a lot of reasons that aren't very satisfying to the participant you are explaining it to, and blaming your unwillingness to do it on vague things that are outside your control like "insurance requirements" or "the law" is a tried and true white lie to get them off the phone.