BG5150

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.

Don't withdrawals from Roth have to be done pro-rata, after-tax to earnings?

The reports I use, only show the aggregated %. There may be a report that shows actual vs attributed, but I'm not sure what it is. I'm sure that you could create a report with that info with Crystal Reporter.

No problem. I am, after all, Bartman.

if the soon-to-be ex-spouse is okay with receiving no benefits from the plan, he or she should have no problem signing off on a beneficiary designation that names someone else.

Or, absent guidance in your document, you make the best estimate you can, document it, and be consistent from year to year.

Has Mr. Churn been appointed by the Trustees to provide investment advice to plan participants? Or is this relationship outside of the plan?

All three should be showing 100% if they are coded correctly.

Amend to remove J&S from the plan, but require spousal consent for whatever you'd like. We have plans that require spousal consent for loans but not for distributions.