Gadgetfreak

Definitely take a look at pensionpro. Their system is phenomenal for CRM and workflow management. You are able to create workflows for anything - including conversions. Full disclaimer: I do NOT use them as I had a custom CRM built for myself just a year before they launched so it wasn't worth it for me. Instead, I am currently looking at project management systems that will help with my conversions. We use Excel now but are looking at Smartsheets. I want to be able to send reminders to the responsible party when we are waiting for documents, etc. I will continue to research.

We use RA for daily recordkeeping and trading. On the first day of each quarter, we need to assess the following fees: 5 bps asset fee for custodian 10 bps asset fee for recordkeeping 15 bps asset fee for Broker $125 flat fee (divided pro-rata) for TPA $2.50 per participant fee for TPA We need to do something similar across all plans and we want the fees to be separated on the last page of the statement for the 404(a)(5) portion. Relius has told us that we cannot post more than one fee simultaneously lest we incur negative holdings. At first they told us that we would need to assess a 30 bps fee in one transaction and call it "Asset Fee" or "Custodial/Recordkeeping/Advisory Fee". That wasn't acceptable and I asked why there can't be three separate asset fees (for disclosure) but Relius would know to bill the 30 bps. They eventually told us that we should be OK if we do the three different asset fees at the same time but I didn't get the impression that they were confident with that. QUESTION 1: Do you think we can assess all three asset fees at the same time without any negative holdings? Then they told us that we "might" be able to also assess the base fee at the same time without negative holdings but, again, I remain skeptical. QUESTION 2: What do you think about the base fee? They told us there is NO way to assess the per-participant fees at the same time and it must be done the following day? QUESTION 3: What are others doing? Doesn't seem peculiar to have a fee on the first business day of the quarter and then a second fee on the next business day? QUESTION 4: Is there any way to enter in payee information for these fees so that it is very easy for us to create a report for each broker telling them how much we will be paying them per plan (and a total)? QUESTION 5: Besides this forum, is there another message board for Relius Admin (esp daily trading) users? Thanks for any help/advice.

Is this forum still being monitored? I have some questions about fee processing on Relius Admin and could use some help from my peers. Thanks.

LLC member made a $17,000 401k deferral on 12/27/12 to TD Ameritrade. Their CPA is telling him today (9/11/13) that he earned NO schedule C income in 2012 and therefore there was no way he could have deferred money into the 401k Plan. Is there any IRS guidance on how to handle this? We are asking Relius about our options and will need to call TD Ameritrade but the CPA is saying that there "must" be IRS guidance on what to do. Thx.

Does this mean that, until the loan is offset, our 5500 assets and loan balance will not match the trust reports from the custodian? That could be years of irregularity. I understand the above reasoning that the 5500 should match the 1099s. So, if a 1099 was issued in 2012 (for example) the 5500 should reflect the deemed distribution then. But the fact that it is staying as a loan balance on the recordkeeping system is going to cause enormous confusion for future years. Does anyone have any advice? Thanks.

Look at http://www.shoretelsky.com/, http://www.broadviewnet.com/, http://www.signalpointcommunications.com/.

You are too nice . I agree that, in the situation you described, it is reasonable to "ask". But as the year gets later and later, I feel more comfortable with doing the match and the ADP test - especially if they do SCP (and no IRS fees).

I agree with your comments. But an SCP (or even a VCP with a mea culpa) correction could be to do the match formula (which is in the SPD so, theoretically participants know about it) but NOT to automatically pass ADP. I think that is reasonable and the "punishment fits the crime".

My understanding is that the Document must say Safe-Harbor Match (SHM) AND a notice must be given prior to 12/1 of the prior year. So this leads to a good question, what if you have the language in the Document but you didn't give the notice? My understanding is that you must still do the SH matching formula but you don't get an automatic pass for ADP. Would anyone like to comment on that?

I have looked at them all. PensionPro seems very promising. However, withany system that is "off the shelf" you are limited to how much customization you can do to meet your specific needs. So, when evaluating, see what system will bend to your needs instead of making you change to its design. Although, in some cases you may find that its design is more efficient than your current process. Each of the three systems you mentioned were designed by TPAs. In addition, look at non-TPA specific systems. A Document Management System (DMS) with workflow capabilities (and a client portal) may be better for you. Since TPA workflows are very document-centric, you may have better luck with a system like that (which typically allows for more customization). For example, as TPAs we get a distribution form or a census from a client and it goes through many stages of a workflow before it is fully "processed". Finally, for a little self-promotion, you may be interested in attending this: http://www.asppa.org/Main-Menu/confswebcasts/webcasts/091813.aspx.

BG5150 is correct. For cross-tested plans, a resolution is needed each year with the allocation by participant. The easiest way I found to do this is to make the resolution more generic and reference an attached schedule (which will be the allocation report).

This is an extremely expensive endeavor for small TPAs. Even small recordkeepers, who I agree need to have "something", will find this a burden. As a recordkeeper, you could provide the SAS70 of the recordkeeping software (ASC, Relius, SRT, etc.) and of the financial custodian which has been accepted by some auditors in the past. In addition, you may want to look into the CEFEX certification program for TPAs and/or recordkeepers in collaboration with ASPPA: http://www.cefex.org/Index.aspx?PageID=28. That has been very helpful for us in providing the confidence that the auditor, etc. need.

My Firm provides added hand-holding when necessary but we really depend upon the client (or the CPA, Adviser, etc.) to be responsive to our communications. For example, if I send instructions on how to electronically file the 5500, we have procedures in place to send a reminder in 30 days, 60 days, etc. As the deadline gets closer, we will call on the phone. But we have some clients that won't return even our voice messages which leads us to send letters stating something like "If you don't follow our instructions or return our calls, we will not be held responsible....". We, for example, do not sign 5500s for our clients. Maybe there are some other TPAs that do. But, if your client is really interested in "doing the right thing", they need to be aware that there are several things per year that require their attention and action. A good TPA will lay that out for them (and remind them periodically). I also wonder if a client like this is careful with depositing deferrals in a timely fashion. I have found that to be the biggest problem as there is a question on the 5500 which specifically asks that. Most of the national recordkeepers don't monitor this or send reminders that a payroll deferral contribution is due. A client like this might benefit from that added service. Some TPAs may monitor this for the client when using the big recordkeepers but I have not seen that very often. Perhaps looking for a small TPA/Recordkeeper that offers that hand-holding may be a good match for this client. Good luck.

But it specifically says "...if the plan is top heavy, all non-key employees must get the top heavy minimum allocation, not just the NHCs...". Wouldn't that include non-key HCEs?

Now this conversation got me confused. Admittedly, I can't think of any plans I currently manage that exclude HCEs from the SH but this is an interesting topic. However, I believed that, to be exempt from TH in a SH Plan, all non-keys must received the SH. After all, if the TH test is looking at keys vs. non-keys, wouldn't one reason that you could not discriminate against ANY non-keys (including HCEs) to satisfy the TH requirements?

We use www.yousendit.com.

I agree with Belgarath.

I do not have an answer for you but appreciate you posting this. I can reasonably say that the work involved in processing a forced IRA rollover is more than a standard distribution. However, reading the above, it seems like I am not allowed to charge a higher fee for this extra work. Can anyone comment?

This was discussed at one of the ASPPA break-out sessions last month. One of the main things they said was most loans have non-assignability clauses in the Document/Loan Policy which would prohibit transferring loans. I don't have experience with Corbel Docs to comment on that though.

It is not so easy when statements could be a different number of pages for different participants. You need sophisticated systems that either can read bar codes or other type of recognition. I haven't found affordable companies to do that in the NY area. But, truthfully, I am not sure where to look. Hence my post. It actually may be cheaper in other parts of the country so I don't need to stick to a local company.

Forgive me for placing this post in this forum but the Relius forum doesn't seem to get as much activity. I can make a reasonable argument that it belongs here anyway so here goes: We use Relius for daily val. Now that there are such stringent requirements for electronic delivery of 404a5 notices, to fully comply with the letter of the law, it would be easiest to mail statements. Dealing with electronic delivery to terminated participants is very difficult. So I am looking for a printing company where I can batch send my Relius statements and they can print, fold, stuff, stamp and mail out. There must be other recordkeepers that do this. Potentially, I can use this for my annual 404a5, QDIAs, SH notices, etc. as well. Does anyone have any ideas? Thanks.

So it has been 7 months since my last post. I think I am one of FTW's biggest fans. As I stated before, I started using them for 5500s when I left Relius in 2009. I liked them so much I started using them for 1099s. Then documents (I used to use Accudraft). And now, just 2 months ago, compliance testing and annual vals (I used to use Blaze) as they updated what I needed for it to work for my needs. Their support is TOP NOTCH. Although I remain concerned that it might get worse now that they were taken over by WK, I have not seen any indication of that to date. They are so helpful and go above and beyond to answer technical questions that are not necessarily software related. Janice is amazing in her patience and fast response in training and helping teach Admin. They have a few JDs on staff too who are so nice and helpful. Their web interface is not that "prettty" and could be a bit more functional (i.e. switching Plans in admin requires going to the home screen and then selecting client, plan, admin - so 4 clicks) but it is extremely user friendly. They know they can improve and I am sure they will at some point. Having all the software integrated is really nice too so you don't need to duplicate (though you may have that already with Relius). Their pricing is very competitive and I hope they don't get too greedy after their acquisition. All I can say is that it is really a pleasure to work with them. I feel that they are my partners, not just a vendor, and they treat me really well. Almost like we are one big happy family. The fact that their "giveaways" at the ASPPA conference weren't that great shouldn't deter you . They did offer massages though. If you need any specifics, PM me. So far, as you can tell, we are extremely happy.

As an independent recordkeeper (on Relius) who just sent out the quarterly participant statements including the one-page attachment at the end with the actual fees charged to the participant accounts, I realize we are at a complete disadvantage compared to the major recordkeepers with revenue sharing arrangements. They only have to disclose those once a year and buried in an extremely complicated notice which I am sure no one will read. But then their quarterly notices (which are easy to read) show a much lower fee than ours which are generally a pure asset-based fee. For those fellow TPAs who are also recordkeepers, how are we going to compete and explain everything when thousands of participants come banging on their employers' doors?

I don't mean to hijack this thread but I was just thinking of something today that is (loosely) related to this topic. I believe IRS Notice 98-52 says that matching contributions to a safe harbor 401(k) plan must be deposited no later than 12 months after the close of the plan year. Putting aside deductiblity issues, what happens if the Company doesn't make the contribution by 12/31 of the following year? Is there specific guidance from the DOL or IRS? I assume they need to make up for lost earnings. Is there also an excise tax with a 5330? Can they still rely on the safe-harbor to pass ADP? Thanks.

ESOP: I put in an information request to PBI. While I wait, can you please tell me how they get paid their fees (and what are the fees)? Thanks.