Gadgetfreak

My understanding, and I could be wrong, was that if you had a no provisions and amended mid-year to a yes, it is a permanent yes until amended again. The maybe->yes is only for that one year and then reverts back to maybe (as it always has). For that reason, and to preserve the cessation without loss, we did not change our procedures for our clients in light of these new rules.

408b2 and 404a5

Why not just use remote-control software so each person can connect to their office computer from their house as if they are sitting in the office. There are tons out there. Look for Remote Desktop Protocol built into Windows. I believe Google Chrome has a free one too. There are also paid options that may not make you commit to a year. But it is good software to have anyway.

Parent Company 1 owns 100% of Company A which has a standard 401k plan with no match or SH at platform X (200 employees). Parent Company 1 purchases 100% of Company B which has its own 401k plan with a match and safe-harbor at platform Z (with 20 employees). I understand there is a period of transitional relief. In what circumstances could each plan operate individually on their own platforms without any combined testing or BRF issues? Is there something about "separate lines of business"?

We also consulted with an attorney and our Document provider with a similar issue. We started a few SH/Profit Sharing plans in September 2019. We made the effective date 1/1/19 so the PS can be based on full year wages. But, since there was no option to defer prior to October, we made deferrals effective 10/1/19. We were told that the SH - whether the 3% SHNE or an SHM - must have the same effective date as deferrals. So the 3% SH was also made effective 10/1/19 and is only based on wages from 10/1-12/31/19.

I just received and interesting question from a client whose Plan EXCLUDES bonuses from the definition of Plan Compensation: "Participant has a $30K/year guaranteed hours bonus to his base salary. Owner uses the term ‘bonus’, but the spirit of the hours bonus is really to incentivize attorneys to meet a set goal of hours. Since participant's amount is guaranteed for this year (and next), is it fair to say that this should simply be classified as regular salary?" What does everyone think?

Isn't this severance compensation (for services not rendered)? Wouldn't that be excluded from Plan compensation? I don't see where the OP stated WHEN the employee was terminated. Doesn't that matter?

Ahhh. Got it. Thanks.

Larry, I know what you mean but, for everyone else who may not, can you please elaborate on your statute of limitations comment? :). To what are you referring?

I thought that SH comp can only be based on when 401k deferrals were effective. At least that is what a recent discussion with FTW yielded when I was creating a new SH plan now, effective 1/1/19 but beginning deferrals and SH on 10/1/19. And they also confirmed that it didn't matter if it was the 3% SHNE or an SHM - SH is only based on the effective date of deferrals. Do you disagree?

Larry: For #2, why wouldn't a SHM work as well to satisfy TH? Doesn't an SHM satisfy TH if there are no other ER contributions? Or does it have anything to do with the fact that the SHM wouldn't have been in affect for the entire year?

I think so.

Thanks. That is what I thought but wanted to confirm. Maybe they should give a CE class on how to interpret their CE requirements :).

On 10/18/17, I received my ERPA renewal letter from the IRS. It says it was issued on 10/1/17 and expires 9/30/20. To the left of that same page, it says, under CE Requirements: "Annual CE Cycle: January through December". I know that the requirements are 72 hours with a min of 16 per year and 2 of ethics per year. What constitutes each of the three years? Is it 1/1/17-12/31/17, 1/1/18-12/31/18 and 1/1/19-12/31/19? Is it 1/1/18-12/31/18, 1/1/19-12/31/19 and 1/1/20-12/31/20? Is it 10/1/17-9/30/18, 10/1/18-9/30/19 and 10/1/19-9/30/20? I think it should be the first but it is very confusing. Any thoughts?

Even with the FTW Document, couldn't you just say it is a "discretionary formula"?

Anyone have experience with ASC software and the Company in general?

The issue with a per-participant fee being assessed for each participant is that someone with a $100 balance will have a proportionally greater fee than someone with $1,000 or $10,000. But I don't like the first method either. How do you explain to each participant that their fee for this period was $36.27 because you added up all the $25 across all participants and then allocated pro-rata? Next bill will be $28.65, etc. If the participant asks for you to "prove" that their fee was accurate, what do you do? You can show them all the other balances. In my opinion, if you can't assess the exact fee for each participant (which has the challenge I mentioned above), I think it is best for the Sponsor to pay the fee. I know I went off topic because my comments relate to even the first way you were handling this - nothing to do with the MEP. But, after running a RK Helpdesk, I have seen first-hand how participants demand clear fees.

We all know that 10% is required. Can anyone point to a cite which states whether it is based on BOY or EOY assets? Thanks.

Thanks Dave. Not to look a gift horse in the mouth but.....It would be even better if the chart could list eligible CE credits by type: ASPPA, ERPA, Ethics and any of the others.

Your ASPPA credentialed membership has a stipulation that you are deemed to have fulfilled their CE requirements as long as you are current with ERPA. So be careful getting CE credits that are only for ASPPA and not ERPA. http://www.asppa.org/Education/Continuing-Education#who: I am not sure if the quarterly Plan Consultant magazine quizzes are ERPA-eligible. If so, that is a very easy and affordable way to pick up 12 credits a year ($200 @ $50 each): http://www.asppa.org/Resources/Publications/Plan-Consultant-Online/PC-Magazine-Information/CE-Quizzes.

Many business consultants recommend using personality tests when (or even before) interviewing for positions. Even the TPA consultants recommend this. Does anyone have any experience with online services that do this and can make some recommendations? A Google search is not as effective as someone who may have gone through this already. Thank you.

It makes sense but, no offense, I am not 100% convinced . I don't understand why their complicated chart says 2014-2017 though. That is why I was thinking 10/1/14-9/30/17. But tracking off calendar year CE credits would be much more difficult. I am pulling my hair out here (without much left to go). If your interpretation is correct, I have 15 days left. Yikes!

But nothing in writing? I can't find anything that supports either interpretation.

Well this definitely helps clarify. But, not to sound unappreciative, how do you know this?

New question. I went to this site: https://www.irs.gov/tax-professionals/maintain-your-enrolled-retirement-plan-agent-status It says 72 hours over a three year period and each year needs a minimum of 16 hours including 2 ethics. My SS# end in a 5 and I renewed my ERPA on 4/1/14 and it expires 9/30/17. What is the three year period? On the one hand, it seems to say calendar year but the chart shows 2014-2017 which is 4 years. So is it 10/1/14-9/30/17? Something else? I don't know why I am having such trouble with this but I want to make sure I don't miss anything. Thanks.