12AX7

Employer wishes to terminate their SH Match Plan. Would the 30 day notice requirement still apply? I can't see where the proposed regs or other guidance would eliminate the notice requirement. I can understand where the 30 day notice requirement would give participants time to change their deferral election if the plan were to continue as a non-SH, but this action would not apply in a plan termination. If there's relief, I can't see it.

Your question is similar to, "what is the best car to drive" or "where can I get the best steak dinner in New York City". The answer may be different for each person. The best advice I can give you is to contact the various vendors and arrange for either an online demo or perhaps attend a conference where some of the larger vendors regularily attend. No software vendor is perfect, but there are a few good ones out there to consider.

By your question, it's not entirely clear if the deductions were made pre-tax or after-tax. If the deductions were made after-tax, are you asking if these amounts can be retroactively classified as pre-tax and possible amend W-2s etc.?

Plan Sponsor may get a letter from the DOL, at which point you can respond that it's a one person plan with assets less than $250K at the end of the plan year. We've seen these come in prior to EFAST2. It's a little awkward at first for your client, but can be worked out.

I don’t like EFAST2 How about you? Maybe it’s the software or just my clients. I will have to think this through. The DOL said this would be easy My software vendor said this would be no caper. My clients just don’t understand. I wish we could still use paper.

Shouldn't Enrolled Actuaries have the same concern with their signature on the SB out there for the world to see? They seem to have no choice.

You're welcome.

Dino - I'm assuming your using a Windows OS. Go to the printer driver and under the Advanced Properties Tab, choose "Print directly to the printer". This worked when we had a similar problem with other forms.

Thank you.

A client receives a late notice for their 2007 5500. One of the options in the notice is to complete Section 1 of the notice if the plan sponsor has already filed the return. In Section 1, the plan sponsor would indicate their Name, Address, EIN, Plan Year Ending and the last question asks, "Date filed with EBSA and Acknowledgment Plan Number number". Can someone please tell me what an Acknowledgment Plan Number number is? Also, the instructions do not request a copy of the return. Would anyone suggest sending a copy with the response. Thanks.

Thanks. The interest rate would be the same 1 year into the loan (prime + 1%), but the payments go down about $20/week, which is a good thing.

A general purpose loan is taken with a 4 year term. Is it possible to refinance the loan to extend the term to 5 years in order to reduce the required payments? In Sal's book, it seems to be possible but I don't see an example of how it's done. Would it seem reasonable to take the remaining balance and amortize the payments over the remaining term plus 1 additional year? I appreciate any suggestions.

Unless I was the plan sponsor, I would not not consider putting my address on the 5500. I would notify the IRS of the address change so that I don't have to see an ex-client's business with the IRS. Good luck!

The OP indicates that the plan is a SH Match. Nothing should be owed if there were no deferrals. The reference to the SH Nonelec seems to be a hypothetical question, in which case I would agree with you!

Plan? What plan? Who saw a plan? Seriously for a moment...I would argue that for each plan year a 5500 must be filed, but that perhaps is the easy part. I could perhaps see a red flag go up if the plan files a first/final 5500 with no plan assets. On the other hand, if the plan document was executed and stuffed into the back of the filing cabinet and no employee knew the plan exists, then how would you or any other party know if it exists? I'm speaking hypothetically here.

One insurance company did not report an amount for Line 2, but that doesn't necessarily mean the amount is $0.00. I'm finding that some companies report total eligible indirect comp while others do not. I've seen prepared examples where 2(g) is left blank. Specifically, I'm looking at a John Hancock statement. Perhaps because it's a Friday afternoon, I'm having trouble getting my head around the answer for 1a. I'll remember to take my pension pills tomorrow!

If an insurance company received direct and eligible indirect compensation and no other service providers received compensation, what would be the answer to Part 1, 1a ? Seems it should be "no", but I want to make sure. Also, if I leave 2 (g) of Part 1 blank, I'm getting a validation error (missing or invalid entry). I've seen examples where this field is left blank, however Relius would prefer I enter a "0". Can this field be left blank? I appreciate all help.

Thanks Belgarth for the insight. I'm waiting to hear back from the insurance company and wanted to know in advance what I have to look for.

A 401 (k) Plan is now being terminated. One participant has life insurance with cash value. The advisor for the plan wants to strip out the life insurance, place these proceeds into the cash portion of participant's account and distribute the contact without taxation. Is this still possible?

Thanks everyone for the replies.

Thanks Sheila for your reply. My concern is where two or more participants want to invest in the same managed group of funds, and the plan offers several managed fund accounts. I don't want to do daily valuation, but would like to offer this service perhaps using a third party record-keeper. I believe something like this does exist, but don't know exactly where.

I'm arriving to this discussion a little late, however I don't think it would be required to submit for a DL if a pre-approved plan were being used. IRS had commented on the same issue at the ASPPA conference last Novmeber. Take a look at 6.05 of Rev Proc 2008-50 (page 32) and the memorandum from Michael Julienelle dated 3/11/09. If the plan is individually designed, then I would otherwise agree.

Does Schwab offer participant record-keeping services? If not, what are options for TPAs that don't do daily record-keeping? Thanks.

I'm of the opinion to not use Form 5500-SF. I prefer not to expose my clients to marketers and that's the beauty of the EZ. It keeps your clients anonymous. Maybe I might consider using an SF for the final plan year? At that point, it would not matter for me if I'm no longer doing work for the client.

Our recordkeeper vendors cannot handle the option you're describing. If I were tracking loans manually, then I would perhaps consider other options. For the most part, participants are happy with any additional amounts we can get them, even if that means amortizing the replacement loan within the replaced loan's term.