BG5150

So it looks like we are NOT supposed to put the D's into the count for question 6. Didn't we used to? Was it ambiguous? The instructions say: Do not include any participants on line 6a or 6b who were previously reported on a Form 8955-SSA or a Schedule SSA (Form 5500). Accordingly, only those participants who are listed with an Entry Code A on page 2 should be included on line 6a or 6b. Seem clear, right? I hate Late Fridays. My mind goes to mush.

This is no different than if the people were not in auto-enroll. Missed is missed. At least it's only a couple months, right? Was this the first entry date this happened?

Can the Plan Sponsor name a position with the Employer as a Trustee, instead of specifically naming someone? For example: The Trustees shall be the President and CFO. Secondly, does the Trustee have to agree, in writing, to be a Trustee? I see a lot of plans where the husband owner is Trustee, and that his wife is also names as a Trustee. What if she doesn't even know that she is Trustee and something happens?

I would not net them together. You cannot pre-deposit deferrals. Why was the duplicate deposit still in there? The funds should have been moved tot he suspense account and used to offset the check/wire of the next payroll.

Without a doubt. We put a caveat in our year end letters saying we can only vouch for the reasonableness, not the accuracy, of the match in such cases.

I don't see why not. Don't forget, the SHM must then be deposited no later than the end of the following quarter.

But, what if it's a partial distribution, and there is money left in the account after the requested funds are liquidated? Could the o/n fee be taken from the remaining assets? Using my line of thinking above, probably not. What do the carriers do? I'm not sure.

masteff-- re-reading the thread, I think you are right. A delivery fee is probably optional where a processing fee is not. I was thinking of the processing fee. I think the delivery fee is taxable. My thought process. Account balance 20500 Distribution request comes in 50 processing fee taken (participant has no choice) Balance remaining 2000.00 Participant want the 2000 paid directly. Taxable amount 2000, w/h 400, net distribution 1600 But wait, participant wants the check overnited. OK. Carrier takes 20 for the overnite fee. Participant gets 1580

Based on the OP, it's not the match that's supposed to be the Safe Harbor. So, you can't impose a last day rule on a non-Safe Harbor match if you are providing the 3% nonelective to everyone?

My thought on why the "fee" should not be part of the distribution, nor part of the 1099-R: This is money that the participant cannot take constructive receipt of; they will never have access to it. It will never be their money. So why tax it?

I'm sure different firms look at it differently. Indeed, there may be differences in charges for separate clients of the same firm. I've billed many different ways. You can make a case for each of the models. It's up to the managers to try to hit the revenue sweet spot that covers the work done but does not strike the client as onerous. Whether it's done on a plan level, client level or enterprise level, it's up to the powers that be.

"Nobody goes there any more. It's too crowded." "Eighty percent of the shots that come up short don't go in." "When you come to a fork in the road, take it." "Pair up in threes."

I was thinking if there were key EEs who had a deferral. There might be TH issues. Maybe not, but could be.

Any key EE's?

Got me.

If I transfer, say $20,000 to a Qualified Replacement Plan, I understand that I need to allocate not only the $20k, but also the earnings to the participants (within 7 years). However, do I HAVE to allow the QRP suspense account to accrue earnings? Can it just sit in a cash position like a forfeiture account?

From an IRS publication: (emphasis mine) From: www.irs.gov/pub/irs-tege/epch602.pdf‎

Then I don't see how the plan (particularly the participant's account therein) can pay the fee.

You give that advice a lot. Should your client's be worried? Nah. The money is coming from the forfeiture account! Well, as long as it isn't real money just forfeiture money then it is ok. I know, right?

You give that advice a lot. Should your client's be worried? Nah. The money is coming from the forfeiture account!

Are we getting mugs again? (BTW, I'm sipping tea from the 17th anniversary mug right now.)

Does EPCRS even address the forfeiture/suspense account directly? Do you think you could self-correct? How long has it been going on? Significant errors cannot be SCP'd after 2 years (I think). Could this be considered insignificant? Section 8.02 gives some parameters to consider.

pad your bill!

I would think that withholding is optional, with a default of 10% absent an election.

Side note: the EPCRS fix can only be done under VCP. SCP is not available.