BG5150

Just make sure you have a deferral agreement in place before the end of the plan year.

Here's the IRS page on renewal: http://www.irs.gov/Tax-Professionals/Maintain-Your-Enrolled-Retirement-Plan-Agent-Status Or, you can call them: http://www.irs.gov/Tax-Professionals/Contact-the-Enrolled-Retirement-Plan-Agent-Program

I don't think I'd go through the time and expense of VFCP for this. Make the correction, document everything thoroughly. Make sure you and your client have a copy and move on to bigger and better things...

To me, VFCP is for late deferrals (and loan payments) to the TRUST, not individual accounts. After that, you are really just correcting the accounts in the manner of EPCRS--get the plan situated as if the error didn't happen. For the earnings, how are you determining that? In an individual account plan, it may be easier to determine the individual rate of return for everyone--have the investment company run a statement for everyone. How long has this been going on? If it's less than two years, then, even if it's a significant error, you can self-correct, I believe.

It could be that the investment house people are mixing up "direct rollover" with "direct transfer."

If all the money is in the trust and nothing is late, why are you bothering with VFCP?

What someone does with the proceeds of a second loan is up to them. As long as the document allows for two loans, I think you are good.

It must.

Sure. Why not? One or two more sentences in the letter. Maybe save some questions down the line.

Wait. Is it an ACP failure, or did they just put too much into someone's account? Two different corrections...

I think for '08 it was optional and then it was taken out for '09. Maybe optional for '09 and out for '10.

What does the document say about the allocation? Two-step or 4-step. You'll find your answer there.

You added a comma at the end of the url. That's why it's not working.

I think the onus is on the plan sponsor. As an individual, how could you go about proving you DIDN'T get paid?

Especially on a $1,200 distribution...

What I would do: (if $3,500 is not a significant portion of plan assets) Put the $3,500 on the 5500 as a late deposit. Pay interest to the trust (or to the individual account if applicable). Submit form 5330 and pay the tax on the interest. Notes: I wouldn't change the W2, as the money was withheld from his paycheck. No remedy under EPCRS for this. No need for VFCP on this.

Sure. But not before 59 1/2.

Available how? For hardships? If the doc allows, yeah.

I'm just thinking back to my days at a big provider. We would get instructions someone passed away and got the bene info. Would open an account for the bene and transfer the funds to that account and leave it there until they told us to move it. I guess I never thought about 1099s which were done automatically. Nowadays, we usually only get instructions when the bene is going to take the money out, so we are always issuing the 1099s.

So why isn't it just a in-plan transfer? I don't see it as a distribution and subsequent rollover in.

Any control group or ASG issues?

Isn't just a beneficiary transfer w/in the plan? Or are there separate plans?

FWIW, auto-enroll plans have 3% rates.

(And let me know where he finds it, so I can start serving a new market...)

1099-R. Beg and plead to have it allowable in 2013 rather than 2008.