BG5150

But if the assets are at a recordkeeper, doesn't the Schedule R usually reflect the payor ID of the recordkeeper? So, it's not really the ID of the plan, but of the custodian who paid the benefits.

Time to make this plan a Safe Harbor Match plan.

Why not do months? It's so much easier. For example, if it is 60 days, Someone hired on February 1, won't be eligible until May 1. Their 60th day is April 2. If it is 2 months, they enter April 1. On the flip side, someone hired July 2 or 3, they enter the plan Sep 1, as their 60th day is August 31 or Sep 1. If using months, it's October 1. It is MUCH easier to just do months. No counting involved. But as you can see, you can have different results. Most of the time it won't matter. But there may be outliers like the situation above. Using months, you can just look at the date and know when the entry date will be, without having to actually count the days.

Under your reasoning: Someone may not "need" the entire amount for the semester tuition bill; they can just take a loan. Someone may not "need" that facelift or tummy tuck, so it's not an acceptable hardship request.

Thanks. Just realized the company is based in New York County (NYC). But still covered anyway. Appreciate the help.

A decline in the market, or plan assets? They don't always move in the same direction. Also, could be problematic if there are assets in the plan for which valuations aren't readily available.

Is there Hurricane Ida relief for 5500's? Company involved is based in NJ.

But if you re-value for one, don't you need to do that every time someone asks for a distribution mid-year? That could get costly.

In cases like that, does teh plan allow for partial withdrawals at termination? Most of the plans I deal with are all or nothing before retirement age.

This guy gets me.

How much is the difference? IS this a small plan filer? If an SF, and if the amount is small, I'd just adjust the earnings for 2020 (or 2021 if '20 has already been filed), make a note in the file an move on.

Keep in mind, this all needs to pass non-discriminaiton testing. Remember, son-in-law in NHCE. Any other employees? I don't remember the exact original question.

This man gets me.

[EDIT] Aw, man! I had like six paragraphs of great insights and code citations for you! Now I had to delete them.

How much does the son-in-law make? He could be HCE via compensation.

My bad. Good point, guys.

But wouldn't that amount be way higher than the deduction limit for Employer contributions? Gross $100k, then after SE, comp around $92k. Then only about $18,400 given the 25% limit.

But are counted as included but not benefitting for the three coverage tests.

Does the plan document address the issues? Absent that, I would think it's the usual 12 months after PYE. However, be mindful of the 415 deadline which is 10/15 (or is it 10/31?) of the next year.

Are you talking about the Irrevocable Waivers? I didn't think they were allowed any more.

Can the cost of the Fidelity bond be assessed to the plan (from forfeiture) and/or participants?

TPA produces annual 5500s. Client constantly indicates on annual data request that no contributions were submitted late per DOL rules. TPA enters zero on the proper line of 5500/5500-SF. Later it is determined that the client has been depositing weekly payrolls only once per month for years. TPA brings this up with client, they say they don't have any money to pay lost earnings or to pay TPA for calculation. They do not want the item listed on the 5500 either. What is the TPA's exposure for producing the 5500 with no late contributions when in fact there were? The TPA is not signing the 5500.

What about sources that are not 100% vested? Do the funds that go tot he AP come from both vested and non-vested portions of the account? For example, PS only. Participant has $10,000 and is 50% vested. DRO calls for 50% of vested account balance. After the transfer, is the participant left with: A) $2,500 vested and $5,000 unvested? B) $3,750 vested and $3,750 unvested? Choice A would be much harder to record keep, IMO.

I would say no. It is not a plan expense. Plus, the expense is beyond the plan administrator's control, and therefore the PA cannot determine if the fee is reasonable. And the PA cannot control where that advice comes from. Could I ask my broker for advice? My brother's wife who works in finance at her company? My buddy, who's broker is EF Hutton, and EF Hutton says... (Only those of a certain age will get that last reference)

Best would be to contact their support directly, no?