BG5150

The contributions are funded by the employer, the r/k doesn't front any money. The R/K pulls the funds via ACH they day they receive the contribution file. Sometimes that is before the participants get paid. I thought deferrals to the trust had to be from current, not future income.

Like group annuities?

Found a r/k who posts deferral transactions before the check date. Basically, they process the contribution file when it comes in. For example, they processed the 5/9/25 payroll on 5/8. I didn't think they could/should do that, but they said it was ok. Do you agree?

ADP refunds are not particpant-driven transactions. The decision is made by the plan administrator. The custodian should rely on the representations of the plan administrator and/or trustee in cases like these. Most of the record keepers I dealt with took direction from me (acting as 3(16) Plan Administrator). But I don't see why they can't/won't take direction from the Plan Administrator. Are these brokerage accounts?

If so, is there a stock report I can run? Do I ahve to get my backend team ro create a crystal report for this? More questions: I think maybe I'm asking if there is a rate of return report that can be run with ad hoc dates? Could it be run on a plan-wide level but with participant detail? The accounts are daily-valued in the Relius ecosystem.

I guess in a narrow view, nobody HAD to explain it to the ER. It's up to them to understand the plan document they are signing, and they are the ones (usually) tasked with operating the plan. However, I'm guessing someone approached the ER about setting up the plan and steering them to a SH arrangement. Whoever did that should have at least explained it to the ER the mandatory contribs and the conditions under which they would be made. It's certainly possible that the ER just tuned out and/or only heard the PS part of the funding. Or maybe thought the SH and PS were the same... I guess they can remove the SH for '26 and just do ADP testing. And tehy doen' even have to give refunds! They can do a QNEC. And guess what? Those don't even have to go to those employed on the last day of the year either!

Did no one explain this to the client during plan setup?

Is there something in EPCRS that addresses the issue of an Employer mistakenly deducting (from a paycheck) and depositing Roth funds for a participant when the ppt's election was pre-tax? In other words I would correct this int he same manner as in my example above, regardless of its relevance to catch-ups.

If they don't want to change their address, change it to mine. I'll gladly accept the check...

In that book, in the bio, it mentions some all stars (Mike Preston, Larry Starr, et al). And also the PIX message board. Good times, indeed!

I was straightening some things up around my house this weekend. Part of it involved moving some books from one bookshelf to another. I came across Who's the Employer: A Guide to Employee and Aggregation Issues Affecting Qualified Plans by S. Derrin Watson. I hadn't picked it up in a long while and I was wondering just how old that book is. Turns out, it's a second printing from 1998. My boss gave it to me in like 2000. She had another copy. Maybe the second ed.? I'm wondering how much has changed from 1998 to the current 8th Edition...

Is there a way to get the job listing posts out of my stream? I find they are clogging up my feed.

If it's owner only, why not just add it anyway?

Then how/why were they reclassified as catch-up? My understanding is they would have to go over: Regular 402(g) limit. Nope. ADP limit. Nope. Plan imposed limit. Nope. Then why would they be 're-classified' as catch-up? These are my understanding of catch-up rules.

How did you do this? Was there some limit they exceeded?