52626

Model allocations are vey common in our plans. Most of the time the funds within the models are different than the core options. We are in the process of updating the models which means fund replacements and changes to the target allocations. Is the plan sponsor required to provide a fund change notice 30 days prior to fund changes to the model. Participant A elects the Moderate Model. The investment strategy does not change even though the funds that make up the model change, so I do not see why a notice must be provided. If a notice is required, can it be sent elecotnronically and then mailed to those particiapnts without email addresses?

Plan allows safe harbor hardships. The participant has medical expenses from 2012 that are not covered by insurance. When the hardship was submitted to the recordkeeper, they denied the hardshsip stating the IRS requires the invoices be within 3 months or less. Is that true?? If so, is there a site I can refer to regarding this matter.

the discussion can up because several participants defer the maximum early in the year and do get the maximum match. Several particiapnts will hit the 402(g) limit by 3/15 and under the terms of the plan they would not receive a match allocation after 3/15. The employer has decided, this was not fail, so they wanted to change from a match being made on a payroll basis to an annual match. They would continue to match each payroll period, but true up at the end of the plan. I was unsure if this change from payroll to annual could be accomplished in 2013 or if the amendment needed to be wait until the 2014 plan year.

The plan document currently states the safe harbor match is made on a payroll basis. The employer would like to change this to an annual basis. Can the plan be amended in midyear to allow with this change

What is so frustrating about all of this, is the vendors all say something different. According to JH the FAB issued in May states You MUST disclose the actual amounts. They were not going to redo their templates for the 8/30 deadline, however by November they plan on including the actual fees in under the general admin section.

As a TPA we completed a form 5330 for 2010 late 401(k) deposits to the Plan. We have elected not to charge the client for the completion of the tax forms for 2010, 2011 and 2012. Do we still sign as the Paid Tax Preparer and show the PTIN number?

The excise tax for late deposit is less than $100. The VFCP Program states if the amount is de minimis ( less than $100), the excise tax is deposited to the Trust and allocated to the impacted participants. Question: If the Plan Sponsor is NOT filing under VFCP, does the di minimis rule still apply? If so, what happens to the filng of Form 5330? Since the tax was deposited to the plan, does the Plan Sponsor just maintain the form for future reference in the evnet of an audit, or doed the form still get filed with no payment?

Since 2004 the ADP Test has been run using Current Testing. However, the doucment stated Prior Year testing would be used. Looking for some suggestions on how to correct. Do we use VCP and have an amendment to the plan stating current yaer was the testing method for all plan years after 12/31/2004? The plan is definately outside the SCP time period. We are trying to make the correction as painless as possible for the Plan Sponsor.

If an employer sponsors a 403(b) with a match, do the deferral deposits fall under the same DOL timing as 401(k) plans?