BG5150

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.

About the only "pass" you get with the brokerage account is the fee disclosure and investment comparisons for 404(a)

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.

Add to that the liquidity issues.

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!)

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!)

Asked and answered here.

EPCRS has the correction for missed deferral in an auto-enrollment plan, I think.

Tell them to go the the courthouse this week and get hitched.

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

What address does she put on her taxes?

And the cost!

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.)

Has the plan consulted an ERISA attorney to see what might be done? Has someone called the DoL to see what they have to say about it?

To the OP: is it worth it to try to find a new auditor who would file a "provisional" audit and amend once everything is corrected? The current auditor is holding the plan hostage, causing (potentially) thousands of dollars in fines. Don't the auditors know that a VCP filing takes a long time to complete?

We just use dead drops around town.

If there are SSNs on the report, are you even allowed to mail it (in certain states)?

Repairs to the home are only allowed for a hardship if the expense is otherwise deductible under Sec. 165 and is not covered by insurance.

Still gotta file 5500's if plan is Frozen. From the IRS: (emphasis mine) https://www.irs.gov/retirement-plans/employee-plans-compliance-unit-epcu-completed-projects-project-with-summary-reports-frozen-plan-amendments

Mike, great idea! I did find it there. 2007 & 2008. (I only have a free account). So it looks like 2008 was the last one they filed. The EIN matches the one Jim sent me. Same Plan administrator, too. Odd: 2008 the only benefit code is 3E (back then, it was the code for prototype). 2007 only had 1A and 3E. I sent Jim a link to the form on FreeERISA.

By law, the participants must be furnished with a paper copy of the 5500 and supporting documents and schedules upon request (after payment of reasonable copying costs). Does that apply to DB plans, too?

What does "fully vested funds" mean in this case. Just the vested balance? Could you ever take a loan from "non-fully vested funds"?

Cite, if possible? (checking EOB now)