BG5150

So, out of luck for two years: 2016 & 2017.

You could, but you would need to get all the underpayment rates and for which months they applied. Someone in my office did one, but I cannot find it at the moment.

Could it be considered a spin-off? Otherwise, anybody leaving a MEP would be out of luck for a year.

When does the document say the deferrals start in the new plan? If BOY (7/1), then do you have a problem that no deferrals were taken until December?

Call Sungard.

Only if the document provides for the exclusion. You can't just not contribute a SH to an HCE b/c you feel like it.

A SH plan has to be at least 3 months, I thought.

Mike, I don't KNOW it. I guess it's just been in the docs I've been using and figured it would be in all of them. It would make sense. There I go applying sense to stuff.

I got one from Tom. It was the one I was looking for. I will save it at home, too, so if and when I change jobs I won't have to ask for it again. It's 5 owners and 4 companies, but it does what I need it to do for now. Thanks, all.

too late for an 11-g amendment

Any prototype or VS should have provisions to address the auto-increase situation. If it is not clear at the moment, there should be choices under the plan to make it more clear without having custom language potentially taking it out of VS status.

This still doesn't change the fact the owner has access to an investment house that the staff doesn't. Could this still be a BRF issue?

Who will monitor the fees to make sure they are not excessive?

Why would you want to destroy contributions? ;)

First off, if the owner is the only one who has a balance big enough for the outside brokerage account, then you are most likely failing BRF. However, offering a blank canvas to the other participants is problematic, too. Is the owner willing to take on the fiduciary liability that would come with monitoring all the possible accounts? First off, I think that fees could be an issue. All the accounts must be in the name of the trust. Is the owner going to set those up, or at least get involved with that? Is there a way the owner can use his clout to get the boutique firm to lower its entry requirements for his firm's employees?

(I really wasn't serious about telling the guy to quit...)

Why would the RK do that? They want the funds in the market so they themselves can make money, passing a little of it off to the FAs

A reason (some) financial advisers are against loans is that they take assets out of funds for which the advisers may be getting paid.

No it won't. That would only be the case if the participant pays the entire $10,600 back at the very end of 5 years. Maybe we did win him over a bit. Plus, loans could be a GOOD investment. In a down market, your loan repayments can often buy back shares at a lower cost that when you originally bought them. (Not that I advocate this as an investment strategy, just pointing out that taking a loan is guaranteed to be bad.)

Does anybody have a decent spreadsheet I can use? I no longer have access to TAG.

Tell him to quit if it means that much to him.

An example from the clip in the OP: Participant has $10,000 in Match, is 60% vested and terminates in 2010, leaves money in plan. (assume no earnings) At the end of 2015, $4,000 is forfeited per the 5 BIS rule. Account balance is $6,000. Person is rehired in late 2016. The $6,000 must be kept separate, as it's fully vested at the moment. Any new match is still subject to the vesting schedule, starting at 60% in 2016. After 2018, the accounts can be recombined (assuming participant accrued a YOS for vesting each year). This has nothing to do with buyback of forfeitures, as others have said.

Setting the first one up as a qnec is an option, but keep in mind the withdrawal restrictions.

I believe so. I've seen plans where spouses and or children of owners were excluded from SH.

The payroll system is wrong.