BG5150

"I'm not gonna tell you if I'm married or not, but I really, really want to cover this lady who lives with me and shares my last name."

What we came up with is this: The person is now eligible for the distribution. it would be counter-productive to have the money replaced to just have it withdrawn again. We'll put a note in the file stating the position and move on.

What would be sufficient, then?

Plan allowed a participant to have an in-service withdrawal before his time. (allowable at 2 years of accumulated funds or 5 YOP, but both only from 100% vested sources). participant was 80% vested at the time. EPCRS seems to say that we could fix this by: 1) adopting retroactive amendment under VCP; or 2) have the employer take "reasonable steps to have the Overpayment...returned by the participant...to the plan." For #2, what are reasonable steps? just write a letter? (BTW, the money was NOT rolled over) Are there adverse consequences to the participant if he doesn't pay it back?

Hopefully, you're not doing a true-up 8 years late!

Well, never mind on the "room" question: http://benefitslink.com/boards/index.php?/topic/39376-hardship-withdrawal/ But what about the "board"?

As far as I can see, the regs say a safe harbor hardship reason can be payment of "tuition, related educational fees, and room and board expenses for up to the next 12 months." Does "board" inlcude off-campus housing? Do you get a copy of the rental agreement and see what the monthly payment is? How do you account for "board"? Estimate monthly food bills? Is there somewhere in the code that spells out room & board?

Pros: front-loading is not a problem for the EEs Cons: mid-year raises will cause a true-up

There are several reasons (for me). (In no particular order) 1. Career. I may or may not be at my current company for the next 10 years or more. The CPC designation is a helpful line-item on a resume. 2. Professional. It can't hurt if and when I'm brought in to help woo potential clients. 3. Closure. It's a sense of "finish what I started." 4. Education. At least with the modules, I have a deeper understanding of some of the topics I deal with day-to-day. 5. Initials. The more the merrier!

Do they pay up front or do they reimburse you? If the former, maybe you can say, "I'll front the costs if you reimburse me when I pass." This way, there is no risk on the Employer's part.

Is that a cost thing? Or they think you are so busy that you can't study for more than one at a time. I found that the 5 months I took was enough time for the first 4. (Though I kind of lollygagged through April & MAy and had to buckle down in June)

Are these mandatory after-tax contributions, perchance?

Lots of trepidation pushing that *Submit* button. But passed! 2 more modules and the Exam to go!

Can anyone point me to the most recent guidance on the elecrontic delivery of the 404(a)5 notices? I thought it was EITHER the "usual" rules under 2520,104b-1(c ) OR the alternative rules TR 2011-03R. I was informed there is more recent guidance, but can't find it.

Usually the document preparation has questions of disposition of the forfeitures in the SAME year or the year AFTER. I've never seen a year BEFORE option.

For a small fee, I'm sure, the amendment can be rescinded or changed to reflect a later date.

3 out of 3 passed so far: Investments Fiduciary Topics Distribs & Loans To go: Related Groups & Business Transactions

ING does this. It doesn't lose much, but can and does sometimes. I thought it was odd, too.

This is something I never understood: The SMM (in this case) would not have to be delivered until July 31 2014. So, in theory, it could be over a year before someone could find out about something like this? How does that work? Should the ER have to tell people about this right away? And if they do (via payroll stuffer postcard, say), why the need for an SMM?

Rollover. That's what it was. First line of your excerpt is also a clue: (emphasis mine) This wasn't an obligation of the employer.

Crunch time! Due by Friday! 80% done.

In a bear market, a (shorter-term) loan can be a boon, as you will repurchase shares at lower prices than originally sold. It's a type of market timing that may or may not work out for the participant.

GMK, I think the allowance for loans stems from a (perceived?) participation issue, rather than a benefit at retirement issue. Offer the opportunity to have at least some access to the money and more people can be induced to participate. Good for the employees--they are saving for retirement Good for management--more rank & file participating, the better for allowable HCE deferral rates Good for asset providers--more assets under management, income from fees (though that offsets the AUM) Good for the brokers/agents--more commissions Good for the TPA--generate fees for processing and administering loans Good for the economy--proceeds from loans going to either pay off debt or purchase goods and services Good for CE providers--yet another webinar they can charge for See a downside yet? I don't.

But setting standards stifles the creativity of the auditors. Who wants audits where all the same parameters must be followed? Not me. My fees would suffer. I'd be spending a lot less time preparing for and responding to auditor requests, thus lowering my billable hours. I think we need MORE ambiguity, not less!

You can apply it to just new people. On many pre-approved document platforms, there are choices to pick that accomplish just that.