Andy the Actuary

little glops If you put everything in the single pdf for accountants opinion, you'll get a validation error if you've indicated there are assets held, etc. and there's nothing in the little glop slot. Thank you. Is this an EFAST2 validation error or a Relius error message. If a Relius error message, can Relus still produce an xml file, which will be accepted by EFAST2? Your explanation was my suspicion. The auditors I deal with appear to be anti-glop and also anti-reading DOL instructions. My hardfast position is to maintain integrity of the process I will in no way, shape, or form alter the attachments they send me. Thus, when they have sent me there auditors report and say everyting is there, I go back to them and have asked for little glops. Owing to my pertinacity, they are finding it difficult to sit down after dealing with me. Actually, this is exciting since I feel as if I am returning years of tit-for-tat. More seriously, I believe if I do alter their attachments, then I am looking for trouble if DOL rejects.

The same ransom world survivalship was held for?

From our favorite EFAST2 Q&A: Q27a: Can I encrypt or password-protect the PDF files? No. A PDF that has been encrypted or password protected to restrict editing, printing, or viewing can not be included as an attachment in your filing. If you attempt to include such an attachment in your filing, EFAST2 will remove that PDF from your filing and you may receive an error indicating an attachment is missing. So, an accountant sends me a pdf, which may have been dumped from software rather than printed to paper and scanned in. I can open it and using handy/dandy Adobe Acrobat Pro 9 crop it, use the typewriter function, and likely other things. But, I cannot edit text a la "touch-up?" The accountant certainly hasn't password protected or encrypted. However, I suspect the PDF writer nukes the possibility of editing text created by a different owner. Will this pdf be rejected? If so, must the attachment be printed out and then imported via a scanner?

Computer programmers are fine. It's the systems analysts (who have no user experience) that deserve the credit.

I'm using I file for DB plans. Edit Attachments breaks down all of the auditors exhibits. Must you add as separate attachments or will IFILE accept a filing where you've simply attached the Auditor's opinion and it clearly labels the exhbits? Thus, one glop versus 4 or 5 little glops (e.g., opinon letter, 5% transactions, assets held, footprint of first born).

Assuming this is a DB plan, can part of the contributions be attributed to 2008 (and 2009 redone)? My understanding from Jim Holland (who?) was that exise tax applied each year until deducted so situation is to be considered only as last resort.

And no doubt you recall Thomas Paine's famous soul trying quote and Paine wasn't even an actuary.

This is my personal approach and should not be inferred to a generally accepted principle: (1) All calendar year 5500s are being placed on double secret extension; and (2) The 5500s will not be submitted until October 15 at 11:59PM. While I'm being facetious, nonetheless there is value in waiting. For example, the following came through about pdf attachments in the July 15 BenefitsLink newsletter: http://www.relius.net/News/TechnicalUpdates.aspx?ID=522. The problem is it's not immediately clear what is meant. Do they mean you shouldn't password protect -- i.e., require a password to open -- or does this mean the pdf shouldn't lock out others from changing it? Based upon what has been said about Relius response, it's doubtful one can obtain a reasonably quick answer on this one from Relius. In short, it may be worthwhile in the first year of EFAST2 to take your time.

Here's an earlier thread that may prove useful. I would presume you would add any clarifying attachment as a pdf to the glop that is being filed electroncially. http://benefitslink.com/boards/index.php?showtopic=10750

It's working great because I haven't submitted any IFILEs yet! All of my calendar year plans are on extension. I'm allowing time to gain user feedback on BL message boards. However, I seem to be able to assemble the xml file with attachments just fine and it looks ok when I view it with IE. I paid for Web client and 10 days later DOL recanted on demanding client sign digitally. Relius does not appear amenable to refunding my $.

The plan document doesn't address this specific situation--participant dies post-application, but before annuity start date. the plan doc has a typical 50% QPSA payable to surviving spouse if participant dies in service with a vested benefit. Are you saying the plan does not specify the QJSA payment form???

Just to make certain: Does the Plan state that the automatic payment form (i.e., the QJSA) is the J&100% or the J&50% and the J&100% was simply an optional form elected? If the J&100% is the QJSA, then the plan conflicts with the regs. The next question would be does the Plan have a D-Letter? If so, guessing no disqualification on the plan language. In any event, get an ERISA attorney involved. If the J&100% is truly an optional election, then no problem with the Plan but there may be a communication issue. What regarding death was told to the participant/spouse when the election was made? In this situation, something must have been written, in particular, since death was imminent. In any event, get an ERISA attorney involved.

Assets are technically pooled whether physically housed in separate buckets that are all part of the same trust. I.e., the gross investment income would be allocated among the buckets. Whether or not a book separation of assets is maintained depends upon whether or not the multiple employer plan was in effect prior to January 1, 1989. My recollection is that employee transfer among employers sponsoring the plan does not trigger a separation of employment for benefit purposes. If separate allocation of assets is maintained, guess is transfer of liabilities and assets would occur in the accounting. Suspect this may have been covered in a gray book question.

FASB discount rate is established by the client and auditor. Would urge that you do not recommend.

Au contraire. Every day above the ground is a good day unless you're an onion.

You ask why you have to email me separate pdfs of all the attachments when the information is in the audit report pdf you were so gracious to provide. I agree all of this stuff is contained in the audit report and preparing separate attachments is redundant and causes discomfort when you sit down. My suggestion is to voice your complaints not at me, the lowly messenger, but rather to the DOL, IRS, American Academy of Actuaries and anyone else who couldn't care less about utility, anyone's inconvenience, or client expense, let alone your humble, professional opinion. Alternatively, you may wish to take a ball-peen hammer and repeatedly strike the middle of your forehead.

I am using Relius and will file via IFILE for single/multiple employer plans of fewer than 500 participants. Sooner likely rather than later I thought I might muck this up. I created the checklist in a mad attempt to protect myself form myself. Feel free to use as you please and please comment if you find omissions or routinely needed attachments. EFAST2_5500_Filing_Checklist.doc

So, this means that the scan of the first two pages of the 5500 are added as other in this manner, since there appears to be no specific slot?

Suspect you will discover that 5500 was not timely filed.

Not restricted to PPA. Indeed it's not. "It is the invariable habit of bureaucracies, at all times and everywhere, to assume...that every citizen is a criminal. Their one apparent purpose, pursued with a relentless and furious diligence, is to convert the assumption into a fact. " - H. L. Mencken Wonderful quote, thank you. May have been ghost-written by Will Rogers.

Our grandchild has decided she wants to become a pension actuary so I bought her these:

As my "from" implies, I'm from the mid-west. However, had the pleasure on several occasions to here Mr. S. It was a pleasure NOT to hear, "Derek Jeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeter" announced.

I'm an idealist. I prefer to think that my clients pay me for something of value. How naive of me!!!!

I both understand and agree with this analysis. However, the situation I described is one where the Plan sponsor wants to pay its lump sums. In fact, I would likely resign if they failed to request a certification as this would truly be flouting the law.

Today is National Venting Day so let me be the first kid on the block to whine. In following the AAA's approach, I've notified the client to request me to certify the 2010 AFTAP for a plan that was frozen 12/31/2009. The plan is sponsored by an extremely profitable not-for-profit organization. The plan's AFTAP has always been above 100% (In fact, they dumped a lot of money into the plan so they could make lump sum distributions to a couple HCEs). It is now 122%. It appears PPA's effect is to punish everyone whether or not a crime has been committed.