BG5150

How is the match calculated? Payroll or annual? (Not deposited, but what's the basis for the match. The plan doc should have that.)

Why tempt fate? Do the extra 5 minutes of work.

How many of your clients do you think peruse their 5500 before signing it?

Two scenarios: 1) the RMD wasn't enough--do another 2) the RMD was too much--all you have is a small "we didn't withhold enough" problem on the distribution over the RMD

So, someone who was putting money into the plan all along needs the money and is penalized with half the profit sharing, whereas someone who isn't putting anything away at all get the full benefit? Something like that might not discourage hardships, but participation altogether.

Where does it say all the participants own each investment pro-rata? If the trust is all in mutual funds, and my account by coincidence is 1/20th of the total, you wouldn't liquidate 5% of every asset when I cashed out, would you? Why is it any different if a building is part of the mix?

The document can use either compensation. I just worked on a plan that added 401(K) October 1, and we used just 4th quarter comp. for the K and full year comp for the PS.

Our bonus election form says something like: "take x% from my bonuses. This election will stay in place until changed."

And ask the custodians to stop sending you the paper copies. Most will be happy to oblige.

For 2012, the ship has sailed, I think. is it a new comp plan by any chance? However, you might be able to amend the plan in 2013 to do what you want it to do.

Is there really mandatory state withholding?

Did the participant not get a copy of the amortization schedule? Did the participant not get quarterly or annual statements with the loan balance? I would not say the fault lies entirely with the plan sponsor. Who did the year-end reconciling of the plan? TPA? Bundled provider? Someone should have seen this person was really behind at the end of '09. '10 the latest.

EPCRS says no corrective contrib is too small. Distributions, yes, but not contributions. And it looks like the net error is $54, so a $27 QNEC plus earnings and full match on the $54 (not a QMAC) to be made if applicable.

Or you can print them to word and modify them that way.

Have you asked the document provider their take on it?

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...