12AX7

Just saw this post now. Perhaps a little late. What did you end up using? I only had to do one and used "Hurricane Irene Exten. (IR 2011-87)" due to space limitations.

I would read this very carefully: http://www.dol.gov/ebsa/disasterrelief.html

There is always a final filing of Form 5500-EZ, even though the plan may have met the Title 1 exemption for filing in previous years. This may bring the plan "onto the radar screen" so to speak. There is no program yet for late 5500-EZ filers. Best for the client to get his late filings in order prior to the announcement of any program for late filers.

If Abbott and Costello did a routine on controlled groups, it would probably be similar to what you have written above. You can't make this stuff up ! I'll try to look at it in the morning.

Can you find another $300 of work to do for the client to avoid the TH allocation, which would likely cost more than that...?

My point is that the SHNEC would not always otherwise satisfy the TH minimum where 416 would apply. This could happen where the eligible employee enters mid-year.

Would there be instances where the SHNEC would otherwise not satisfy the TH minimum, when 416 would apply? That could also be their thinking...

Are they all members of a controlled group of companies?

I'll miss you Tom. We had some good chats during the conference. This could be my last time in attendance as well. I may retire or semi-retire in the near future.

Well done, Tom ! Are you doing another performance at ASPPA this year?

Janet got it. She wins a large case of satisfaction. We'll have to work on a punchline for Tom's joke... Actuary recognition is getting a workout on the Identity Guard® commercials I'm hearing lately on the radio.

I will tomorrow...stay tuned !

Why do kids that are into heavy metal music want to become actuaries when they grow up?

How does one switch without changing the opening numbers on the Schedule H, or can you change the opening numbers?

I have plan that I took over in 2010. The Schedule H was prepared on a cash basis. I typically prepare these schedules on an accrued basis to coincide with the IQPA schedules. I don't see anything in the instructions that would would prevent me from continuining to use this method, even thought it's not my preferred way of doing things. Can the form be switched from Cash to Accrued, of am I stuck on cash for eterniity with this plan?

We do. Our notice does reference Hardship Distributions, but only that these amounts cannot be rolled over. I think you're supposed to provide the notice prior to any distribution, if I'm not mistaken.

Party on Garth !

Assuming you have exhausted all reasonable methods to get the data and you are getting the same results, you may want to think about getting rid of them as a client. Just curious, are they still paying you?

Standard Disclaimer: I'm not an attorney, and I suggest that you or the client check with legal counsel to determine if any of the following language is suitable for your particular situation. RESOLVED FURTHER that in the event a participant fails to complete a Distribution Election Form or cannot be located after all reasonable search methods detailed by the Department of Labor in Field Assistance Bulletin 2004-02 have been exhausted, the Corporation may utilize distribution options suggested from the Department of Labor’s Field Assistance Bulletin 2004-02 (see Attachment A). What I did was just flesh-out the framework for the language that I basically use. I sometimes futher detail the IRA custodian, timeframes for a participant search, or other details, but that's not too important at the moment. Perhaps there are better ways to accomplish this. Again, please keep in mind, this is not *all* the language in the resolution I may use, but I typically build around this framework. End of disclaimer, crazy ideas and my ignorance for the moment...

Austin, when I'm a-terminatin' a plan, I put language into my a-terminatin' resolution that references the FAB, and what happens when particiapants do not return benefit elections for whatever reason.

I've seen it both ways, with most signed as an individual. I had to convince one audtor that using a fancy font was not acceptable. I'll leave it be with the signed name of the accounting firm.

The DOL has a "wet ink" signature requirement for the report. Is the signature required in an invidual's name or can the name of the firm just be signed? This is from the DOL's website: Attachments Q24: How do I attach the report of the independent qualified public accountant (IQPA report)? The IQPA report needs to be documented on letterhead, signed, and then saved as a single Portable Document Format (PDF) file. That PDF file then needs to be attached to the Form 5500 annual return/report. When you submit the Form 5500 annual return/report, the attachments will be transmitted to EFAST2 along with the rest of the information in the annual return/report. It doesn't seem clear how that signature should be done, so it seems that the name of the firm, would be sufficient? Thanks.

Thanks Nicola !

Thanks John. That's what I thought, but wanted to check. Up to now, I've only done submission of a single document.

Plan sponsor did not amend for EGTRRA and GUST and does not know if he initially adopted a TRA '86 document. My idea was to submit all three documents under VCP as a non-amender. My question is regarding the fee schedule for submission. There are between 51 and 100 participants in the plan. Is the fee $2,500 for all three documents or $2,500 for each document submitted under the program? Thanks.