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Everything posted by BG5150
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Anecdotal evidence tells me most ERs do NOT read anything we send them.
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The docs at my former company ran about 80 pp. It was a VS in an IDP format.
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The pdf for our BPD (from Relius) is 110 pages. The AA for a 401(k) plan is 48 pp. including appendixes. The SPD, including cover page & table of contents runs 20 pp. Loan policy is 2 pages. It is a VS w/ adoption agreement plan.
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My hire date with my current company is 1/1 even though I did not start until 1/4.
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Maybe you should contact one of those good advisers you've seen.
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Hardship Distribution
BG5150 replied to Belgarath's topic in Distributions and Loans, Other than QDROs
I agree. 30 yr old "child" is eligible for h'ship. -
KInda, sorta, like when they call the 3% non-elective a "match"
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Bird, many firms, especially older ones (or, rather, those run by older folks), still refer to their profit sharing as a "distribution" of Employer funds to their Employees.
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Distribution paid by employer not plan
BG5150 replied to pam@bbm's topic in Correction of Plan Defects
I think that would only work if the ER did not file its taxes for 2016 yet. -
Satisfying ERPA CE requirement
BG5150 replied to Cynchbeast's topic in ERPA (Enrolled Retirement Plan Agent)
NIPPA? CEEBS? CPA? -
I have several clients that either have a platform/SDB or SDB-only setups. I do not have any clients that allow their participants to invest with any brokerage they want however.
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About the only "pass" you get with the brokerage account is the fee disclosure and investment comparisons for 404(a)
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Even if the NHCE accounts were sufficient to invest in the high limit investment, I think you would have to look at total account balances as well. An example: Investment minimum: $15,000 Owner account: $250,000 Average NHCE account balance: $20,000 If the HCE invested the minimum, she would be only putting in 6% of her balance. If the average NHCE did so, they would be forced to put 75% of their balance in. Doesn't seem feasible given the DOLs penchant for diversification.
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Add to that the liquidity issues.
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Unless you are making your own tomato sauce, most jarred brands have enough sugar in them already. (This was quite the departure from SH contrib timing!)
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Does the plan administrator not get annual reports from its TPA? Or record keeper? They should. And on one of the reports should be a YTD amount of deferrals & match & SH. The deferrals should be easy to check: Add up the deferrals on the W2's for the past how many ever years and compare it to the deposits. Unless this goes back many years, or there have been several record keeper changes, it shouldn't be that hard for just one participant. (Heck, the participant might even be able to check the deferrals himself!)
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EPCRS has the correction for missed deferral in an auto-enrollment plan, I think.
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Tell them to go the the courthouse this week and get hitched.
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I agree with Bird. You don't put self-directed accounts (whether they are brokerage accounts or those held at one of the big "record keepers") on the SAR. For the pooled portion of the assets, you only need to list the companies and how much is held at each place. For example: Merrill Lynch $1,300,504 Charles Schwab $704,608 Santander Bank $100,000
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What address does she put on her taxes?
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Satisfying ERPA CE requirement
BG5150 replied to Cynchbeast's topic in ERPA (Enrolled Retirement Plan Agent)
And the cost! -
Satisfying ERPA CE requirement
BG5150 replied to Cynchbeast's topic in ERPA (Enrolled Retirement Plan Agent)
ASPPA regional in Cincinnati in November. (It's really across the river in Kentucky.) -
Or, roll the audit dice and hope they say: well, it was the HCE who didn't get it, so it's ok. (Note: This is NOT my recommendation. I am not saying you should ignore the regs.)
