HarleyBabe

Like your thinking:)

Would providers such as FT Williams have access to those prototypes and what about the determination letter? Would I also submit for determination? Add to that, the 5500s have never been prepared properly when asked the required contribution question. Not sure on that one yet so if you have direction for me for that fix, it would be appreciated. FTWilliam is a fairly new company, so they wouldn't have any prototypes pre-dating the GUST restatement, but Corbel will. It appears as if you already have a TRA '86 document since that is what the plan would've been written to in 1992. You should ensure that the sponsor amendment for OBRA' 93 and all good-faith amendments (add-ons) are incorporated into that 1992 document. So, you're basically looking at a GUST document and EGTRRA document (while ensuring you include other post-EGTRRA-restatements such as RMD) in your submission. You can rely on the opinion letters for these adoption agreements, so you wouldn't need to file for a favorable determination letter. Even though they've never filed a Form 5500, you should still be able to ascertain a count. The Fees for the filing are typically based on the participant count, but it appears as if it's a small employer so they will likely be under the $750 fee. Should be pretty straight forward since you won't have restate to a TRA '86. A GUST document should be easier to find. Good Luck! What about PPA, we'll need that too? Gosh, so I will need 3 documents basically. Thanks for this direction. Documents have always been done by another party, so this is my first go round on correcting.

Took over a plan that is a Money Purchase. The Form 5500 has never checked that it's subject to the minimum funding rules section. Plan has been effective since 1983. Can someone please give me direction on this as far as what should I do, if anything, other than say I wasn't responsible for those years and move forward? I feel I need to give them the option of correction and also tell them to have their former TPA pick up the cost. What correction options is there and how far back?

Would providers such as FT Williams have access to those prototypes and what about the determination letter? Would I also submit for determination? Add to that, the 5500s have never been prepared properly when asked the required contribution question. Not sure on that one yet so if you have direction for me for that fix, it would be appreciated.

I have inherited a Money Purchase Plan and a 403(b) Plan. The money purchase last document was signed 1992. There is no 403(b) doc. My concern is the MP doc. I want to be sure I am understanding VCP. Because it has missed many regulatory updates, I am assuming, that I can simply restate the plan completely with a brand new document currently which will include Tra 86, Gust, PPA..... and use the streamline VCP approach. That's the first question. Second question is, do I have to also submit for determination letter as well with the VCP? It appears based on one of the appendixes under VCP, that I do because it's one of the steps and goes on to state that you have to send 2 separate checks.... I want to be sure I'm not missing something when I explain this to the client. The 403(b), which is a non-Erisa 403(b), I am doing a document now. Haven't really seen a correction program for that. Any advise as I have a meeting tomorrow 9/6 in the afternoon and I"m trying to gather all the info. Thanks.

Much more confused. It's the same Employer offering each plan. I'm not sure this addressed my documet questions. What documents do I need for this SEP that the employer is offering, meaning is what is their obligation for plan documents vs 5305?

Have a plan that has a SEP, note they also have a non-ERISA 403(b) SEP was originally established with a 5305 years ago. Also, looks like a doc was put together in 89 of some sort nire looks like an spd. It has an integrated formula for the contribution. At some point the TPA firm realized that doc had old language in it and amended for law changes. I don't really think it ever had an approval letter or anything like that. I am now trying to make sure they are compliant and am not sure what direction to go, ie just complete a 5305 current and it's requirements as per the instructions or are they ineligible for this form and must use a prototype plan. I'm unclear based on the instructions on the 5305 if they are ineligible for this. They have the 403(b) but not sure if that is considered another qualified plan which would knock them off the 5305 and it's integrated so it's not a uniform percentage of comp. Just not sure. Can anyone offer assistance and if we have to amend onto a prototype, looks like it has to be submitted to VCP?

This is where I am confused. How do I track the basis if part is subject to tax but not subject to Federal. If I have a total dollar amount being deferred for a year, how do I account for it in the plan so when it's distributed, I can say that so much has already been subjected to state tax. I can't split it up and say this amount is prewitholding and this amount is post. It's one thing when you contribute ie Roth or 401(k) and they are in whole either prewitholding or not, but not a little of each.

Just had a question about salary deferrals for PA residents. Have a PA resident whose employer is in DC. Apparently PA salary deferrals are subject to State tax but not Federal. How does the employer handle that when withholding and submitting contributions to the carrier? Thanks

Help - I am in need of E & O for my firm. Every carrier I call seems to have no clue what I am talking about because I do not invest. We are just a straight TPA Firm, you know, plan design, admin, implementation, forms.... Can anyone send me some info or give me a company quickly. Thank You.

It does help. Thank you very much.

I too would like a point of reference for the TPA and what to provide. Is there a good site to use to find this info with examples.

problem is, I"m coding the doc and 58 and 10 isn't an option. It warns me that it shouldn't be less than 62. Using an FT william Doc, How would I code the doc. I can add a custom sectio nthat won't throw it off their prototype. They, meaning FT Williams support, suggest putting an early retiement in.

Was given a last minute document to do and racing a little. I haven't had to prepare the docs before and have a question about the NRA. Their current doc had a retirement age of 58 and 10 on part but no later than 65 and 5 on part. Question is, how do I accomodate that first piece. I don't believe that is allowable any longer is it?

thanks all. Yes I will be changing this combination 403(b) plan an Sep plan quickly. I can put the document together for the 403(b) plan but what about whether it's ERISA or not. I just don't know what to do about that and it makes a big difference on 5500 filings or not. Will I have to go through a correction program since there has never been a document if it's non Erisa? Any direction on where to go looking for the SEP rules other than the IRS site. I'm assuming the reason for both of these were so that no forms had to filed and to save on admin.

I have recently taken over a client that has a 403B and a SEP, yuk. I am not versed that well in either but in regards to the 403(b), currently held at T Rowe, I am trying to determine whether this is a true ERISA plan or not. The CPA guessed when completing a service agreement with T Rowe and put no however that wasn't based on any real knowledge. The plan is deferral only. It again is offered through T Rowe where by the participants can pick from a group of funds. All our eligible and that is all that is known. There is no plan document nor has there ever been. This actually all came to light as I was trying to determine information on the SEP plan which those questions go in another forumn I suppose although if anyone knows the answer to the easiest way to amend a SEP document that hasn't been touched since the early 90's and what exactly I need to provide participants each year and if I need to go through a correction program because no real documentation was ever kept, that would be great please reach out to me. Actually I have all the same questions for each plan. Just not my cup of tea and need direction and confirmation from the research I have done. Thanks

so yes, I think?

Does a refinance for a principal residence qualify for more than 5 year amortization?

I have a situation where I have 5 different locations for an employer, same industry, 1 owner owns a piece of each the others are all different, and I'm not sure if I have an issue with the above. I don't believe it's a controlled group. I was directed to someone but really didn't want to pay the hourly fee for the answer so I'm hoping someone here can help. Also, the entities are all S corps. Entities are counseling centers in different states, so different patients, staff.... Here is the breakdown: Owner 1 2 3 4 5 6 7 8 9 10 Location 1 45 45 10 Location 2 50 50 Location 3 30 30 30 10 Location 4 33 33 33 Location 5 60 30 10 Owner 1 wants to establish a plan for Location 1 for now. With the other locations adopting the same plan later or their own plan. Thoughts? No owners are related. I don't think it's a controlled group, or an affilliated service, but muliple employer I was concerned with and if so, what next. I'm in the midst of setting this plan up.

I apologize if I am in the wrong area but I am trying to find contract work as a TPA starting her own business to tide me over until the clients roll in. Does anyone know where I should look or go or who I could contact? Thank You and feel free to email pensionpros@comcast.net. Thank You.

If anyone can recommed an EA that will work via contract and sign my 30 1 to 3 man B's and Aftap's and such and not charge me a fortune, please email me. Pensionpros@comcast.net. Thank You.

thank you. Yeh, doesn't appear that MD is one of those.

If an individual who is ASPPA credentialled leaves a firm to start their own TPA Firm where they will only employ themselves bascially with a small book of clients, is there a state license you must obtain? Or do you just need the E & O insurance to cover you.

Have a plan that terminated January 31, 2008. At that time, we prepared the termination minutes as well as a PPA Good Faith Amendment, Amendments regarding the NRA and Heinz Decision and the other Interim Amendmentd due at the time. We have just been informated that unbeknownst to us, the plan has not distributed it's assets as of yet but because the plan has still been active, do we have to do a full blown document restatement now for PPA even though we did the Good Faith Amendment and all the Interims?

May not be asking this correctly, but I will try. Because of the required amendment for age 62 in pension plans. Those defined benefit plans we have that have an age less than 62, we took the approach of many and that was to have an ERA of the age that we had been using and continuing to base the accrued benefit on that number as well as using it for funding. With the DB restatements, our prototypes don't seem to cover the above. The master document uses the accrued benefit definition as ....to Normal retirement. That is now presenting us a problem for those plans we are restating with throwing it off the prototype. How are others handling their docs?