Gadgetfreak

But I am still trying to find a big chunk of webinars (without quizzes) where certificates are issued. Anyone?

Yes. I just found that on the CE page of ASPPA: FSPA, MSPA and ERPAs:If you are an FSPA, MSPA or ERPA in good standing with the IRS/JBEA with regard to meeting all required CE requirements for your related credential, you are deemed to satisfy all ARA CE requirements. However, all JBEA credits are subject to final approval by the Joint Board for the Enrollment of Actuaries and all ERPA credits are subject to final approval by the Internal Revenue Service (IRS). It is your responsibility to determine the amounts of credits actually earned for each category subject to the rules promulgated by their regulatory bodies and any related codes of conduct.

Oh wow. Even if the cycles are different? My ERPA doesn't need a renewal until mid-2017. The ASPPA cycle ends 12/31/16. I don't need to worry about the proper ASPPA CE credits for 12/31/16? Also, thank you for your opinion on the ERPA credits. I would tend to agree which is why I was hesitant. So I could spend the $2300 for a year of Relius/FIS webinars and just do the live ones. I don't know if I will have enough by mid-2017. Besides bhfe, does anyone know of others where I can listen to a webinar (preferably archived since I need a bunch of credits) and get a certificate. Oh, and without a quiz would be even better . Thanks.

I was looking at the Relius/FIS SmartPass program. $2300 for unlimited webinars for a year. But here is what it says for the recorded ones: Please Note: Due to the inability to track attendance at this recorded event, a Letter of Participation is not provided. So I am just trying to find out if I can self-report these for ASPPA and/or ERPA and, if so, what kind of proof I need. Thanks so much.

I, also, usually get my credits at ASPPA annual but, due to conflicts, missed the last one. So I need some ERPA credits by mid-2017. No more free IRS webinars for credits. ERISAFile used to have an affordable package but it doesn't have it on their website anymore. I e-mailed them for more information. What about from the vendors (ASC, Relius, etc.)? I can buy a package from Relius and even let my staff sit in for general knowledge (not CE credit) but I am wondering if that is acceptable for CE at all. Since it is a recorded webinar, they can't track attendance and there is no exam. So there is no certificate. Is that acceptable for ASPPA and ERPA? How do I prove it?

I want to try to match the fee schedule that Vanguard is using to try to steal my business . They claim $__A___ for the first 15 participants and then $___B__ for each participant over. But they also have bands. I cannot get Relius to calculate the total fee and then deduct pro rata.

Apparently, a recent update now allows for the importing of a specific fee across all plan participants pro-rata. You no longer need to specify the fund or account. This is new. I still can't figure out a way for RA to calculate a fee such as $____ for the first 20 participants with balances and $___ for each additional participant over 20 where RA calculates the total and then assesses the fee pro-rata. Thanks for the information Tom.

Does anyone know how to upload an Excel file that includes just PlanID, a dollar amount, a fee description (for disclosure purposes) and maybe a date to Relius as a Fee Transaction so that it will apply that fee, pro-rata, to all participant accounts? I don't want to upload by fund, source, etc. which is what I see in the help file. Just a straight fee. But I need to upload because I have many plans at once where I need to do the calculation outside of RA. Just for some background: I, and Relius Support, cannot figure out a way for RA to calculate a fee such as $____ for the first 20 participants with balances and $___ for each additional participant over 20 where RA calculates the total and then assesses the fee pro-rata. It can do several parts but not the whole thing. Hence why I need to do the calculations outside of Relius and bring them back in. Any assistance would be most appreciated.

The "per participant" phrasing is exactly the problem. All we know is that the funds took too much in internal expenses over a 2-year period. It is up to us, as the recordkeeper, to allocate to participants.

I am the recordkeeper and can estimate that this will take a long time and wipe out nearly all of the check amounts coming to each of these 10 plans. I found FAB 2006-01 after jpod's post and I like it a lot. The problem is that it isn't exactly the same thing. I need some solid precedent so that, if I am questioned later on as to why I allocated in a certain way, I can rely on previous legal opinions. Clearly, I can't deposit this in the forfeiture account. If I could easily say that it was OK to just divide the check across all current active participants or across all current active participants in the affected funds, then I would even waive most/all of my fees for doing the work (and all this research). But it isn't truly fair. If someone was invested in one of these funds 2 years ago and was hit with higher fees than they were supposed to, they won't see that money now. Is the consensus here that I could rely on FAB 2006-01 as precedence and just go with one of the above two simple allocations?

We were recently notified by a fund company who will remain nameless for now - scratch that, the fund company never contacted us, we started hearing from our clients - that they "mistakenly" charged too much for investment expenses for one of their funds. All of a sudden, my clients started reporting that checks were coming to them in the name of their Plans. The fund company hasn't said what specific period these excess fees covered so we aren't really even sure which participants to reimburse. I will try to contact the fund company to find out but, before I do, I am wondering if any others were affected by this and how they are handling it. Unless the consensus is to simply give it to anyone who is currently in the fund (or stick it in the forfeiture account), this is going to be an enormous project. Who is paying for the time involved (if anyone)? Thanks in advance.

I agree, In this case, the client is sending the money to the RK on time but isn't sending the file at the same time. So it is not the RK's fault. But, based on this thread and what I am reading online, it doesn't seem the client violated the 7-day safe-harbor. As such, I am more confident advising them that they can answer No to the question of whether DEPOSITS were late. Thank you.

I agree with you. In fact, I have found several comments on the DOL 7-day safe-harbor which say something similar to: The regulations also clarify that it is only the deposit, not the allocation or investment, that must occur within the requisite window. Honestly, I am a bit surprised because I would think the DOL is looking to protect the participant as much as possible and having money deposited with the custodian but not allocated to participant accounts seems opposite their intent. But I have a client who had a few late files but never a late deposit and I am debating how to answer the question on the 5500.

We all may know the DOL safe-harbor of 7 days for depositing 401k deferrals. I am trying to find specific language that states that this deadline refers to getting it into participant accounts (i.e. knowing the participant allocations) and not just sending a check to the custodian. Everything I read speaks about check timing, deposit, etc. I have no doubt that the spirit of the law is that participants must have it in their accounts but is there specific language? Thanks.

I found this thread from 2002 and thought it might be time for a new discussion: http://benefitslink.com/boards/index.php/topic/15137-nipa-vs-aspa/ What are your feelings on: 1) The organizations as a whole? Is one geared toward a specific field (RK vs. TPA) or Employer size? 2) What about the credentials they offer? Is one more known and/or respected - either in the industry or to clients/financial advisors? 3) Education (including webcasts)? 4) Conferences? Both seem to have comparable "annual" conferences and now both have business owner ones too. 5) Networking opportunities? As a small-business owner, NIPA has a business owner membership which allows my employees to all have (non-credentialed) memberships under me. Their annual conference is a bit more affordable too. But, to me, ASPPA and it's credentials just has a more recognized name in the industry. I am anxious to hear your thoughts. Thank you.

I had researched that with TAG a while ago and got their confirmation that you may exclude non-key HCEs from receiving a safe-harbor match and STILL get a free pass on Top-Heavy.

What do you think about giving the HCEs no SH match but giving Keys the SH match (along with NHCEs)? I have a client that wants to do that.

This is a great thread to post a question that has been nagging me for quite some time. In a situation where you discover late deposits and convince the Sponsor to report them (both in a filing and on the 5500), when do you self-correct alone, self-correct with a 5330, file under VFCP or a combination?

I have ERISA attorney opinions that don't see any issues with this.The provider is allowed to cut their fees (not getting it from any where else) for any reason. I know of other providers that give preferred pricing for plans with a certain FA if the FA brings X business. Even NW charges plans less if their PPA/TPA has X amount of assets under management.

This is a valid point but I know that we generally aggregate all assets of "affiliated" plans together for purposes of determining breakpoints. I assume that, especially with high assets, similar "deals" can be made with the providers.

That makes sense. But 5(e) is new for for 2014. I wonder how it was handled in the past. Thx.

A Plan had a PPT in 2014. Per IRS, all affected participants became 100% vested, I have read several articles that speak of "red-flags" with the 5500 - one of them being if there were a lot of terminees. Question: I don't see anything on the 5500-SF to indicate a PPT. If so, and the IRS sees decreased participants, where do they also see that it was a PPT and everyone became 100% vested?

I don't know the answer to the original question but what about an example where someone is hired as a consultant in January and paid via 1099. The project concludes in Feb and it was a "job well done". The company decides to offer this consultant a salaried position as soon as the consulting project is over. Is that a possible scenario?

Multiple monitors and Excel vLookup are some of the "more modern" ways of doing what you describe. I am not saying they are better mind you. A lot of it is a generational thing but there are a lot of positives as well.

I agree. But I didn't think that was the original question (i.e. different years).