BG5150

I believe this is the correct answer. Section 6.02(5)(c) Special exceptions to full correction, recovery of small overpayments. (e) is similar.

Participant elected to have Roth deferrals taken. Company deducted funds pre-tax. (However, the proceeds were "correctly" placed in the Roth source at the record keeper.) Crossed tax years. What might the fix be here?

But are there no penalties for late "adoption"?

I would. couldn't hurt. This way, they get the new address earlier.

It's not related match, really. In this case, if the plan matched catch-ups, we wouldn't be forfeiting anything. It's just that some of the deferrals are being recharacterized and moved out of the test.

While reading about not matching catchups and the timing, a thought came to mind. What happens if a plan has match that is payroll based and the company deposits it with each deferral. Participant is an HCE who defers $15,000. After the ADP test is run, it fails and $3,000 is recharacterized as catch-up. Do we have to go back and forfeit all the matches working backward until the $3,000 deferal mark is hit?

Why is that, Bill?

I remember the good ol' days: a decade or two ago, you would call, or go onto the java site and enter a ticket (for Administration, at least) and someone would call you back in a day or two. (Though I often found it funny as they had to know I'm in NJ, but they would leave messages at like 6:30 pm "this is Relius calling...") But you got to talk to the same few folks. They would walk you through stuff right on the phone. And up to about a year ago, you could call, and if someone was available, they would talk to you right then and there. Now, I think these tickets are going to software guys or engineers, rather than user support people--the people who actually USE the software...I heard mention of a JIRA ticket in one of my calls to them. In my experience, that's like the coders' and engineers' workflow. So, I think it's now programmers who are trying to answer questions SOLELY via email/ticketing system. FIS is a huge company, 65,000 employees (compared to SunGard, who had around 13,000. I understand why they want to streamline things (in their mind), but the customer support of the Relius products has taken a nosedive. I've sent emails from a variety of FIS websites complaining, but have yet to get even a response.

to the OP: What if the ER was ONLY depositing 3% through the year for everyone. And then decided to to a 6% PS to the owners. Do you see a problem with that? (Let's assume it passes nondiscrim.) And how would a BRF on deposit timing be tested? Are more frequent deposits considered more valuable? Or fewer? Why?

Well, I just found out the client already paid the fine. (it's not my client, but that of a colleague) But I am suggesting we file under DFVCP to avoid the DOL punishment.

Just saw that plan was filed 2/28/22. Could we "amend" by checking the special extension box? This way, we are truly filing a form that is technically not exactly the same as the one already sent in.

Plan sponsor is not in a state affected by Hurricane Ida. But the TPA office is HQ'd in NYC and other remote workers in Ida-affected areas. Do they still get the extension?

That was my initial thought. Wasn't sure if it would work. The IRS KNOWS it was late without DFVCP. Why would they accept a DFVCP filed after they KNEW the first one was filed late?

But the form was already filed...

Did you not contact FTW about it?

ER filed 2020 5500 in Feb 2022. No DFVC (still looking into why). Got a letter from IRS looking for $22,000. Any options other than pleading for a reduction?

Who knows. It was a takeover for us in March and it was added then. So far, no one has used it. I would think that it's ok to eliminate since 1) they can still make pre-tax deferrals and 2) no one has used the feature yet. But just because there's "no harm, no foul," doesn't mean it can be legally done.

I do for probably 98% of my clients. I have a couple who insist on signing and mailing the forms themselves. I tried to tell them, just sign it and send it back to me, and I'll file it electronically. You get immediate confirmation and it saves you the $4 in mail delivery confirmation fees. In fact, I started several years ago and put the EZs on SF one-participant plans so I could file electronically.

That's correct. Unless the plan sponsor's company has 150 partners and spouses and they all get 1099s and they filed a bunch of 5330's, etc. But why not file electronically? So much easier. And you get an immediate confirmation.

SH plan. ER wants to remove Roth feature effective 7/1/22. Calendar year plan. Can they do that?

One of the Adobe products?

Have one what? Side note, if this is for 2022, almost assuredly someone is getting 1,000th hour this week sometime, if not last week.)

If it's just one person, set up an EFTPS account and send the money that way. Have Schwab send the ER the withholding check and the ER uploads the info in EFTPS. Use code 945. The worst part is waiting for the PIN to come in the mail. Otherwise it's very easy. Then have the trusty TPA do the 1099

Side note. I ran it thru nondiscrim and it works as a PS! Only 1/5 HCE got it. coverage over 100%. Gateway passed and then a(4)

Why do companies put in days instead of months for a service requirement? It is MUCH easier to figure it out with months as the baseline.For example, a plan requires 60 days of service, monthly entry (next or coinciding). Employee is hired July 3. When does she enter the plan? September 1. That's 60 days of service.What if it was April 3? June 1? Nope. July 1. 60 days of service is June 2.If it was two months of service, it's much easier. Anyone hired on the 3rd of the month enters the same day: first day of the third month after hire. No counting days. No missed deferral opportunity. Someone hired on Aril 3 has to wait 28 more days to enter the plan than someone hired on July 3. Doesn't make sense.