BG5150

I'd say 11/30

One of the reasons given was the low cost for entry to a myRA. You can start with as little as $25. What IRA provider is going to open up one for $25? Can you make payroll deductions to an IRA? You can with a myRA.

This just in: US Govn't announces its myRA conduit IRA Rollover product. Thing is, this new IRA has a choice of two investments: a US Postal Service or Amtrack bond. Send a letter or take a train ride and help your account to profitability!

Keep reading. From EOB:

Some outlets refer to it as the State of the Union Speech

For non-ERISA plans, is it incumbent upon the employer to find a vendor who will do that? Or, is it the vendors responsibility to either do it, or find someone who will. From the "Governmental & Tax Exempt Plans" study module from ASPPA: (my emphasis)

Is there a Service Agreement in place?

ASPPA's big disagreement with the SOTUS is that the President disparaged the current retirement system really only benefited the rich, that they were "upside down retirement tax incentives." I wholeheartedly agree. President Bush went down a similar avenue, albeit it had to do with supplementing/changing the Social Security system. First it was Lifetime Savings Accounts in 2003, then Individual Investment Accounts in 2005. Both ideas went no where.

Short answer: no. There are no retroactive deferrals for periods a person was not eligible. Again, the 1% minimum (and the 90% maximum) is on a per payroll basis, not an aggregate for the year.

From what I remember, the only time the 5 yr BIS comes into play for excluding service is if the plan has the Rule of Parity: Parity BIS rule: if EE (1) is plan participant; (2) is 0% vested; (3) incurs 5 consecutive BIS, plan permanently may disregard EE’s prior service So, unless this person was 0% vested, the rule probably doesn't apply.

The deferral rate is per pay period. It's not an overall figure for the year.

Being the cynical guy that I am, I'm guessing they want to do this so the doctor can get a PS for 2015.

True, the DEFERRALS are not included in the ADP test, but the PARTICIPANT is not excluded entirely. They are in the test as 0% ADR. (Same thing with ACP test: in there, but as a zero (if there were no other allocation conditions))

Why would the IRS care if it was eligible for rollover?

I think they were doing it to avoid as much taxes as they could.

In strict terms you have an operational failure. You (the proverbial "you") never allocated the forfeitures. It's probably too late to use them for past expenses (there are threads discussing how far back you may or may not be able to go to use forfs for fees). A primary tenet of EPCRS is to put the plan in a situation it would have been had the error hadn't occurred. Also, if you were reviewing this plan, how would you look at the circumstances that forfeitures were not allocated when the lion's share (if not all) of the amount was to be given to NHCEs, but rather when, now, the bulk of the proceeds (if not all) are going to the owners? It could seem like the non-allocation was done purposely to the advantage of the owners. And again, I don't think you can self-correct this; it doesn't seem to be insignificant.

David, How would you handle this client? Administer it with a 7/1 hire date because it's "on the census" even though you know it's probably not the case? The latter part of that sentence makes it your business.

What does the 5+ years break have to do with this?

Do the seasoning rules apply at all here? Why does he even keep the pre-tax money in there? Move it now, and there's only the '14 RMD to worry about and then nothing more.

Charge him $7,000 for your time figuring this out. This way, you only have to spread around $200. What is the allocation formula?

How far back does this go?

Way to go!

Why would you think it would be okay (excise tax notwithstanding) to return the money to the plan sponsor? They are legitimate forfeitures, no? Not mistakes of fact? Also, I do not think you can self-correct back to 2009--that would have to have been done by the end of '12. Also, I would consider this a significant failure, as there is a pattern of failure, and it could quite possible affect 100% of the participants.

Not "giving" them away. It's $50 for a credential upgrade.

PASSED! Application for credential upgrade submitted.