BG5150

My question is: if the employer has to reimburse the plan, where does the money go? It cannot go back into the participant's account. If not, then where?

I just use A.

If you cannot find it, that doesn't mean there is no plan. He may be lying and saying he has no other employee, and filed an abbreviated form that is not available to the public. Are you a W2-paid employee? Do/did you work full time?

I've often seen A used in conjunction with C, non-farm income.

Were these remaining assets ever reported on the 5500? If they were, and if it's a significant amount, did no one notice that the amount of the distributions were way less than the opening balance of the 2017 5500?

I think that would be more trouble than it's worth.

Would any of the plan communications have ANY participant information in them? Other than an asset statement, what else would have someone's name on it?

Bill tried to find Larry for me to no avail. Maybe on Wednesday. (If I'm sober enough to get to the sessions...lol)

I'm on opposite sides for those two sessions. Nat'l Harbor 11 then Potomac C....

I met Bill, but I think Larry is ducking me. lol

This is what our loan policy says with plans that use hardship reasons for loans. Notice nothing in there about limiting the amount to only the need basis.

There are no taxes on a Loan unless they default. No 10% penalty either.

That provision only limits the REASON for a loan, not the AMOUNT. Look at the maximum available loan section in the loan program and/or the SPD. It probably says minimum $1,000, max $50,00 or highest outstanding balance... It probably doesn't say the amount is limited to the hardship need. So, to me, in theory, you could have a $40 medical bill and get a $50,000 loan.

If a client's plan is excluding leased employees, do you check to see if: A person shall not be considered a Leased Employee if: (i) such person is covered by a money purchase pension plan providing: (1) a nonintegrated employer contribution rate of at least 10 percent of compensation, as defined in Code section 415(c)(3), but including amounts contributed pursuant to a salary reduction agreement which are excludable from the employee's gross income under Code sections 125, 402(e)(3), 402(h)(1)(B), 403(b), 132(f) or 457, (2) immediate participation, and (3) full and immediate vesting; and (ii) Leased Employees do not constitute more than 20 percent of the Employer's nonhighly compensated work force. I never thought to ask if their leased EEs are covered under a MP. And what is the second part saying? Leased EEs must make up more than 20% of the workforce in order to be considered leased and able to be excluded?

Bonds don't cover plans. They cover people. And to answer one of the other questions: I'm guessing the identity thieves opened accounts in the participant's name. Interestingly enough, there is a relevant article to this in this quarter's Plan Consultant Magazine.

I know in an EACA, the plan could have a provision that allows the withdrawal of deferrals within 90 of the deferrals starting. Can that provision be used in a QACA plan?

Worked like a charm! Thanks!

I, too, am interested in this...

Brian Gallagher.

How can I search for a particular user profile. How could someone look up BG5150 without clicking on the relevant link in a thread?

I'll be there, too...my first one.

I'd reach out to support @ftwilliam.com and ask them. They'll know best what can be done and what cannot in the program.

Is there a cost to file? I thought there was, but maybe it's just that we charged our own fee at my prior employer.

...and they are subject to the 402(g) limit.

A few of our clients are getting the "you had late contributions, VFCP is available..." letters. Do you submit via VFCP after getting those letters? Any anecdotal evidence of investigations if is isn't filed? Or do you just keep a copy of the self-correction in your files and show that when asked?