david rigby

Neither you nor the sponsor can "bend" the calendar.

If the church is part of a larger denomination, there may be overall policy (not necessarily rules) that indicate certain level of communication to employees. BTW, even if not subject to ERISA, providing a "pension booklet" can be a good idea, whether or not you use the term SPD.

Good questions, that deserve lots of discussion. Just my opinions: 1. I expect the change to be effective after 2016 (could be 2017 or 2018), and the funding requirement will permit, but not require, a projection. For 417 purposes, it seems very awkward to include a projection scale; IMHO, also not appropriate. 2. I agree, a 50/50 blend of the funding tables is the likely result. I expect to submit more detailed comments, which I'm advised to send directly to Carolyn Zimmerman.

For many, it's difficult and tiring to read everything on a monitor. Errors and/or shortcuts can be the result.

Yes, indeed seek out competent advice. But also take note of inconsistencies from your original post: - If the sponsor really did go "out of business" (yes, this can mean different things to different people), then the plan may have been automatically terminated. - If there is no plan sponsor, it cannot be "brought into full compliance".

IMHO, one tax filing is insufficient, but maybe that's just me. BTW, don't forget to coordinate with the plan's definition of "spouse": 12 months?

Proof? Wouldn't you look to the definition in state law? IMHO, neither the Plan nor the PA should spend anything (other than trivial costs) on this.

Has the 2014 W-2 already been issued? If not, don't issue a corrected form, just issue a correct one.

What does the plan say? If the plan is silent, consider recommending that the plan sponsor amend the plan to remove any doubt.

Ah, the controversial "Carol Gold memo". Does anyone treat it as authority? BTW, a claim that "NHCEs may never vest" is pretty silly, since that applies to every plan.

... and it's OK to advise the (proposed) AP/attorney that the k-plan did not exist in 1995. BTW, you state "divorced in 95" but be careful that not to confuse "separated" with "divorced". It might not make a difference, but it could.

Oh, now I see. Your "these amounts" refers to the AFN; I misread it to refer to the FTAP. w/r/t the AFN, I think the applicable guidance is DOL Field Assistance Bulletin 2013-01. (Does not change my answer. Absent any updates from the DOL, the "MAP-21 Supplement" still exists for plan years thru 2014.)

I'm reading HATFA. Also, see IRS Notice 2014-53 and IRS Notice 2012-61, and IRS Phone Forum 09/27/2012.

As I read it, there was a choice for 2013, but not 2014. BTW, the IRS website no longer publishes "MAP rates" for 2014.

I'll bet there is more to it. - is the participant an HCE? - an employee who had some authority to direct the payment to ex-wife?

Data as of 31-DEC-14 (Wednesday) Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 3.72 3.72 Aa 3.80 3.80 3.80 A 3.87 4.06 3.97 Baa 4.65 4.70 4.68 Avg 4.11 4.07 4.09 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 1.36 Medium-Term (5-10 yrs) 1.84 Long-Term (10+ yrs) 2.52

That's hilarious, whether your misspelling was intentional or not.

Never seen it trigger an audit.

...and tune up the resume.

When the PBGC makes a promise, they are using other people's money. The process is broken.

Careful reading of the plan document will probably reveal (as suggested) that nothing in the document will provide the desired 100% vesting. Therefore, an amendment is required, not just suggested. The amendment could, but does not require, stating any reasons for giving the advanced vesting. Nevertheless, corporate management should be able to succinctly articulate those reasons, if asked.

Having a rehired EE automatically eligible to contribute at rehire date is not the same as having that person elect to contribute.

A few comments: 1. To those who may be concerned about whether the OP violates any rules about public discussion of fees: IMHO, it does not. The posting is by a potential buyer of actuarial services, not a seller. 2. Such rules may be violated if sellers used this thread to discuss fee specifics. But the discussion above involves general comments, not specifics, so (again IMHO) this is not a problem. 3. There is a comment above about "$4,000 is a steal". This is not a fee discussion; it appears to suggest (correctly, in my view) that the fee in the OP is already a competitive fee, at least approximately. Of course, there is nothing wrong with shopping around. 4. In answer to the question, “Is there any third party administrator geared towards owner-only plans…” the answer is YES. In fact, there are many actuaries who work on such small plans but do not work on large plans, and vice versa. I advise the OP to locate one or more of these small-plan actuaries for a fee quote. I’m not one of those, but there are many actuaries like me who are qualified to offer a few recommendations. (Usually, we know a lot of other actuaries.) There is nothing wrong with requesting referrals. 5. I suggest the OP consider the overall discussion as reassurance that the training and experience of a qualified actuary will be reflected in a fee well-above the "button-pusher" level, and you probably will also get some advice thrown in. BTW, the “small-plan” actuaries generally do not work for large corporations that have lots of overhead costs. 6. No details of the owner-employee are mentioned in the OP. Depending on that person’s demographics, the OP may encounter an experienced actuary to advise that the owner-employee does not need a DB plan – yet. In this case, the actuary will give you a brief explanation, and you will understand the explanation and be reassured. Good luck.

If the payments are subject to withholding in the same manner as regular salary/wages, then using a payroll system as the payment tool seems to make sense. BTW, mind the FICA limit.

OK, in theory.