BG5150

I think in an ACA you only have to tell them once you are going to do it. With EACA, you have to give a notice every year. EACA has to be for the entire year, ACA can be implemented at any time. The Sponsor may not want the headache of processing the 90-day distributions.

What do they have against this person deferring? Jeez.

Then find a new TPA. And what does the record keeper have to say about it? Just take the money when we send it to you, take your 20 basis points and shut up.

Page 131? .pdf only has 4 pages!

Just in time for Thanksgiving!

Was 401(k) taken out?

Keep in mind, while the SH Match may be CALCULATED on a payroll basis, it doesn't have to be DEPOSITED every payroll. A SHM calculated on a payroll basis must be deposited no later than the end of the quarter after which the match was earned. For example, the May 5 payroll match would be due no later than Oct 31.

No one got paid for 2 months?

I think this would be more of a company by-laws issue than a plan qualification issue.

Is that a way of getting around the $5,000 force-out rule?

As I said above, my client got one when they filed a 1096 (or 945. I forget which) and the info wasn't the same as a previous year.

We had a client move one time. Add that to we ever-so-slightly changed the plan name on the 1096 and they got a letter saying 2009 & 2010 info didn't match up, and they had to submit the 8822-B to report the "change"

If they employer doesn't want to short those people, they should make an amendment to include the true-up.

That should be standard procedure for everyone.

It's not like health coverage where if you miss signing up you are out of luck until the next enrollment window.

"Entry Date" is when you become a participant in the plan. Deferral election is irrelevant. To me,if you don't sign a form on or before your entry date, you are zero percent. So, then, if the administrative procedure is to allow deferral change for any payroll, a participant can choose to start, change or stop for any payroll period after the entry date.

What does it mean to enroll at zero percent?

Do they have separate IRS plan id's? Eg, 001 & 002?

Then you either have to continue with two plans and pay the yearly admin for both or merge them. Both additional costs. If vesting is not an issue, could they do a flat dollar QNEC instead? Some documents say there is a last day rule for terms.

Because if you don't make the SH most years, you are constantly reminding your employees that you aren't making a contribution. We might. Um. Maybe next year? Nope. Try again. Oh, so close. But here's another notice. Uh-uh, not gonna happen. But you never know...

The company's name is in the SPD in a couple places. So, the SPD is changing. Why not do an amendment and SMM?

EPCRS on IRS site: http://www.irs.gov/Retirement-Plans/EPCRS-Overview Link to .pdf (first link on page) http://www.irs.gov/Retirement-Plans/New-Revenue-Procedure-Updates-EPCRS I don't have a ton of experience with filing under VCP. At my old job, we suggested our clients get help from an ERISA attorney.

Any loan corrections must go through VCP. No SCP.

I put a group like that in my system, even though it's not in the document. It's easier to allocate that way in Relius sometimes.

Pardon my ignorance: What happens if the mortgage goes into default and the property reverts tot he mortgage holder? Is this an exemption to the anti-assignment rules?