BG5150

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.

I don't think they'll let you extend it out 5 more years. That would be a 10-year loan.

Is it that much of a problem to scan three pages instead of just the one?

Side note: no one noticed that their paycheck didn't go down for two years?

Plus, you have to make sure the original loan is paid off w/in on or before its 5th anniversary. There's an example in the EOB.

When the contribution is DUE and when it's DEDUCTIBLE are two different matters. I would say the TH minimum for the 2012 plan year is DUE by 12/31/13. No earnings adjustment needed. As to the DEDUCTIBLE, I would refer them to their accountant. For 415, it is treated as an annual addition1 if it's contributed within 30 days of the due date of the tax return (including extensions). Why don't they just amend the return? If anything, it's a deductible contribution and it must be made.

What else would you do?

Years ago, I seem to remember that a person subject to RMD, the first distribution(s) of the year would go toward the RMD. Not "may" or "can" but "will." If the money is rolled over, the plan satisfied its RMD duty, but there is a problem with where the money landed. (I could be wrong)

Does your service agreement say anything about records retention?

Thanks, Kev.

Where/how do we report CE for ERPA? All I read is that you have to do the credits and keep the records for 4 years. Nothing about how to report it? Is it on the honor system, but you have to have the stuff in case they ask?