Gadgetfreak

Thank you all so much for your responses. You are correct. The email Subject is IRS Enrolled Agent - Renewal Due by January 31, 2026, and it is addressed to "Dear Enrolled Agent." As I am not an EA, I assumed they had just confused this with an ERPA. But now I see the confusion was sending the EA email to ERPAs :). OK. Immediate crises averted. Thank you, Paul, for the link to check ERPA credits and renewal date. I am not so concerned about the credits to date because not all of them are reported directly anyway. When I renew, I report them then. What still confuses me is the cycle for restatements and CE credits. I don't see why it has to be so complicated. My ERPA expires 9/30/26 according to the website. It seems I need to submit my renewal application between 4/1/26 and 6/30/26. On that application, I am to report CE credits from which years? 2023, 2024, and 2025? See the screenshot from the IRS. It says 2023-2026, which is four years. So confusing. Thanks again for everything.

Back to this topic. I don't consider myself stupid, but the IRS makes things so complicated. I received an email this weekend from the IRS that says: Dear Enrolled Agent, Your application for renewal of your Enrolled Agent credential is due by January 31, 2026. If you have completed all required continuing education (CE) hours, please submit your application before the January 31 deadline to avoid a potential lapse in your credential. Your renewal application should not be submitted until your required CE hours are complete. Processing of your renewal application may be delayed if you have insufficient CE hours or incomplete documentation of valid CE. To ensure timely processing of your renewal application, please check your online PTIN account (IRS.gov/ptin) to verify that all CE hours are accurately reported. Continuing Education Requirements: Obtain 72 hours (66 hours tax-related CE and 6 hours ethics) every three years, based on your renewal cycle. EXCEPTION: If this is your first renewal, you must complete 2 hours of tax-related CE for each month of your enrollment, plus 2 hours of ethics each year. Obtain a minimum of 16 hours per year (2 of which must be ethics) CE hours from courses that were taken before the month in which you became an Enrolled Agent are not applicable. Excess hours in ethics cannot be applied toward your federal tax/federal tax law CE requirement. CE must be obtained through an IRS-approved continuing education provider. If you have completed IRS-approved courses that are not posted on your IRS PTIN account, contact your CE provider for assistance. I didn't think I was up for renewal yet, but I can't even see where my current status is listed. Anyway, I go to the FAQs and follow this link: Publication 5186 (Rev. 11-2022) My SS# ends in 5. Doesn't this mean that my renewal APPLICATION must be submitted between 4/1/26 and 6/30/26? So what is this email I got about 1/31/26? And then, I am STILL so confused about which credits I am to report? Each of those ranges in the Renewal Cycle is 4 years. This is supposed to be a 3-year program. Further complicating this, is the fact that the PDF of form 8554-EP is from 2020 and doesn't have the current years. The online form for 8554-EP on pay.gov doesn't give any additional information. So...... 1) Does anyone know where I can see online my official ERPA status and when it expires? 2) Can anyone explain the discrepancy between the email stating I need to submit my application by 1/31/26 vs. everything else above? 3) When do you think I need to submit my application? And what period will the renewal cover? 4) Which years of CE do I need to report on this upcoming application? Thanks in advance.

The issue is more about compensation, I think. There must be many entry-level positions in this field available. But they come with entry-level salaries. Since her prior experience doesn't translate well to this industry, it is almost like she will have to start at the bottom.

I think it is an unnecessary burden on the client/employer. The code should be set up on the payroll side. After all, the recordkeeper can only identify a mistake AFTER it happens. In my opinion, the payroll system should be programmed to handle this so an error does NOT occur. Yes, the RK can be a second line of defense (if the employer provides HPI data), but employers shouldn't need to do that if they don't want to.

I am curious about why the industry doesn't view this as purely a payroll function. While an RK needs DOBs for various reasons and can use them to determine whether a participant's catch-up needs to be returned because they are not the proper age, there is no other reason to collect SS wages except for this new rule. Why can't this responsibility be put on payroll companies to ensure they do it properly? They have all the records.

Looks like it. 18 complaints over the last 3 years. Again, I am well aware of these prospecting companies. I don't like them but I understand them. It is the representing that they work for the current provider that has me worried.

Has anyone ever heard of this company? A client of mine just told me they called her (with a heavy accent) and said they represented my firm and were doing an independent review of the plan. We all know about cold calling based on public DOL data (nothing to do about that) and even scare tactics using the Judy Diamond "score", but saying they represent me is a a new low.

A bit suspicious that the author is not named. How do we know his/her credentials?

Get a full demo with FTW. It does balance forward RK. Their support - even after being acquired by Wolters Kluwer - remains fantastic. The web-based interface is also ideal so there is nothing to install. If you use them for docs, gov't forms and admin (testing/valn/etc) there is a lot of integration.

But remember, even if he IS still considered working, he may need an RMD depending on his key status.

Set up an account on Upwork. Post your project specifications. Received replies/quotes from freelancers who can help you. Interview them and pick one that is a good match. I use PP and agree that it may be overkill for this. An Excel file may work. But, if you want to get fancier, there are many online systems that can be configured for your needs. These freelancers can help build them out for you.

Agreed. If the only way to get a distribution is to wait until after the year-end valuation after you terminate, then you only need to update the participant's records once a year. Of course, if there is a vesting schedule, the balance the employee sees in their SDBA daily might not be accurate. But I get why SDBAs would be better than an annual val as it allows participant direction. Another option we, as a recordkeeper have been doing for new clients is linking Schwab PCRA accounts to our daily system. It is the best of both worlds. Daily RK, participant direction, full fund universe of an SDBA, and no issues with ongoing distributions, sources, or vesting. PM me if you want more details.

Wow. That seems like a lot of work. SDBAs have daily access, and someone could potentially request a distribution at any time. Vesting needs to be updated—as do sources—before that happens. If deferrals are being deposited on an ongoing basis, wouldn't you need to track each payroll for each SDBA often? With pricing coming down and providers offering flexible billing options, I suspect a daily platform would be more cost-effective than a TPA doing all that.

But then you need to be concerned that the plan is set up with immediate vesting and distribution sources are uniform across all sources. But yes, separate one for Roth is needed.

It is so difficult to figure this out and stay on top of it. PLEASE keep us posted.

Erisapedia offers this title for a subscription fee. Very reasonable. Search is great. Plus, I realized that opening the website in Microsoft Edge and then using MS Copilot allows you to ask questions and have it search the site for answers in easily understandable responses. Erisapedia doesn't even need to invest in its own AI system for this.

I received an email like that and, similarly, it didn't work for me. There is no number, name, department or email to contact. I reached out to the IRS agent that I am currently working with on a client audit. He told me the e-mails went out to everyone but each agent will send their communication through this portal as needed. So, if you are not expecting anything now (and he told me he didn't send me anything), he told me just wait for the next time an agent sends something, and then I will be given the chance to access it again. This only sounds somewhat accurate but I don't have the energy to pursue this any further. The next time I need it, I will see what happens.

Thank you.

Can anyone recommend a (paid) service for tracking down lost participants? Thanks in advance.

I am having a similar situation now with an existing client and participant who got a letter from the SSA saying they MAY have a benefit of $200k. The client sees they had a balance in 2007 and terminated in 2005. They have a 2007 5500 that shows distributions of over $800k but, obviously, no participant data. The 2007 has no SSA and they do not have any prior or later 5500s that show this person's name. He has no statement at all - just the SSA letter. So that is the big question - is it his responsibility to show that he has a balance or the client's to show there was a distribution? I think of my own bank account. If I get statements every year showing a balance and then I get one that doesn't, shouldn’t the bank have to prove that they distributed the money to me? Granted, I would check regularly, but this person hasn't done anything in 17 years. But is that a reason not to believe him? I am also tagging @Larry Starr here because he had posted useful information in the thread referenced above and perhaps wants to comment here. Thanks in advance.

If you are (or know) a small TPA (<300 plans) looking to begin a transition to retirement and want your clients to get the amazing service they are used to with a family-owned, well-established TPA firm (currently <1000 clients), please send me a private message. My firm is family-owned and operated, has been in business for 40+ years, and has a full succession plan in place. We have the infrastructure and processes to take on a block of business while still providing the personalized service of a small TPA. If you don't want to sell out to private equity, VCs, or the huge national recordkeepers acquiring TPAs (I am bringing those clients on fairly often when they get upset that they lost the personal touch), we may be a good fit. I am willing to entertain various business structures. Thank you.

They "know someone". Basically a small group of investors who buy properties for income. If they are not receiving any personal benefit from the real estate and offering the option to invest to ALL of their participants, what other concerns about a PT would there be? And I would still be interested in hearing more thoughts on my other questions if possible.

I have a bunch of questions related to this as well. I have a client that has a 401k plan with father/son partners and 3 other NHCEs. They want to ALLOW everyone to invest in a private real estate fund (for investment purposes, so no PT) as a choice amongst other traditional mutual funds in the menu. 1) It was mentioned above that you could do this in an IRA. Is that really possible? Which vendors could handle that? That is definitely better than my client demanding to allow it in their 401k plan. 2) Since it is a participant-directed plan, must the RE fund provide a valuation every quarter? Or is annually enough? 3) What is the requirement for a 5500 long-form vs. short-form? 4) What is the requirement for an annual independent audit? Besides this being "messy”, is there anything else to be concerned about? Thanks in advance.

Maybe there is a second plan that ONLY covers NHCE with identical BRF?

There is also a third option that most (but not all) PEOs allow - a completely separate 401k plan with an outside recordkeeper, custodian, and TPA. Just because the PEO is a co-employer does not mandate that you use their bundled 401k program.