BG5150

In other words, he is key in 2015, and as such, his 12/31/15 balance is considered as a key employee. Also, if the plan is TH for 2015, and if the plan doc does not allcoate TH contribution to keys, he doesn't get one.

I was thinking same thing. Unless ownership is 5% or less.

If the trustee is the record keeper (or a related business thereof) we don't get a separate TIN for the the trust. It usually is at the big outfits.

Who is the trustee?

Oh. If you are not subject to the 70.5 withdrawal in the 401(k) plan to begin with, you don't have to take from the unrelated rollover money either.

Yes. For the year after the rollover occurred.

Here's a tip: tell your clients the deadlines are really a week or two BEFORE the actual dates. This way, you build in a cushion. {note: I have not done this yet, as the idea just came to me, so I don't have any feedback on any fallout)

This is from the Employer Cotnributions section of the BPD: To me, if the contribution is not made by then, let's say 9/15, then we have an operational defect. What's the remedy? Just fund it?

Someone's getting anxious!

We are using a prototype document. It says for the timing of contributions, they must be made by the Employer’s tax return date. What happens if they are late? My guess is that it is an operational failure. But what is the remedy? EPCRS seems to be silent on the issue.

Because I read 'monthly' even; despite the fact it clearly stated quarterly. This is why I always try to explain my reasoning. So, when I am clearly wrong, I you seen what I missed :-) But you're right, it would be 1/1; the first entry date after the 6 month period. Good Luck! Just wanted to make sure I wasn't missing something.

Always use a payroll report. Some states are tougher than others to glean gross comp.

I think way back, when a lot of schedules were cliff, vesting was used as a loyalty tool. If there's a 10-year cliff and you've been there 8 years, would you want to leave and forfeit 8 years worth of PS and earnings? Could be a big chunk of change, especially for the higher paid workers. I think the acelerated vesting schedules, like 3 year cliff or graded shedules became recruiting tools--you won't have to spend 5-10 years here before you start seeing pension rewards.

How is plan entry 12/1 with plan's entry dates at quarterly?

What's the drawback to allocating as additional match? Top Heavy issues?

I there is nothing to say remove funds with earnigns, why do so?

It's been a long time since I've administered a plan that was effective before 1985....

I used "investment experience" as a synonym for earnings as to avoind being repetitive. My question boils down to this: When correcting this type of mistake, is it mandated anywhere that you must include the earnings in the correction, other than 6.02 of EPCRS where it says that the plan be put in the position it would have had the error not occurred?

We have several people who received too much match (per the formula) in 2014. Quick fix is to remove the excess amount from the partiicpants' accounts and have the plan administrator use the proceeds to fund future ER cotnribuitons. In the past, I would include earnings in the amount removed. Someone is now questioning that method. Is there anything that requires me to include investment experience along with the over-match amount? The only thing I can point to is the general correction principle of EPCRS that the plan be put in the position it would have had the error not occurred. Is there anything specific that details what is to be done in this case? EPCRS seems to address mostly under-contributions or overpayment of distributions. Did I miss something there? Should I turn my attentions elsewhere?

Is there a problem using one every year?

An 11-g amendment is used to avoid a failure, not correct one. It's considered a pre-emptive strike. At least, that's the way I've always seen it.

A rollover letter is not needed for balances under $200, as no taxes are withheld and the entire amount is paid to participant. You may want to add something like they have 60 days to roll the money into an IRA (or another QP) to get favorable tax treatment. All others must be given a 402(f) Notice along with the distribution paperwork and an explanation of what will happen if they don't respond timely.

Mike, If and when CAN you use it? Are there any examples or explanations of this topic floating around?

I've always used 14 A as the starting point for figuring out plan compensation. I see a lot of returns have both 14 A and 14 C figures, with C oftentimes quite a bit larger than A. Why the disparity? C is from the 'nonfarm option'. Why the big disparity? All these doctors & lawyers can't all have farm businesses on the side, can they?

I would put it right into their accounts. For the previously-paid out participants, If the amount is less than $200, send a check to last know address (after, of course, reopening the account) with a letter stating they have 60 days to roll it over. Well, it depends on how long ago they got paid out. people do move. Use yuor best judgement. For people over $200 and whose distributions were more than 180 days ago, I would send new paperwork. Less than 180 days, send check in same manner as the last distribution.