K2retire

That would make life much easier for the participant receiving it.

I just had one of those calls. It is helpful to share this info so at least we can sound like we're two steps ahead when we get the calls; thanks. Agreed! When I got my first call about it today the client said, it sounds like you've gotten lots of these calls already -- because I knew about it from the rest of you.

May the prayers of all of us bring some small comfort to you in this difficult time.

They want a "conversion" a "takeover" a "service termination" or service transfer to a new investment provider.

It is my understanding (from years ago, so perhaps it has changed) that safe harbor plans were required to allow election changes every December in addition to whatever other regularly scheduled change times were allowed. I think that is what that language is intended to convey.

It's undoubtably frustrating. But why didn't you keep those quarterly statements, since you also knew about those old DRO filings? After all you have more at stake than the plan's recordkeeper does.

If there is no Schedule SE, there is probably no earned income for plan purposes either.

As I read this explanation, it sounds like you're saying that loan payments are sitting in some unallocated account for a period of time before being applied to the loan. Why isn't the instuction of what to do with those payments made at the same time as the deposit?

Some documents specify that loans cannot be refinanced. Could that be the issue?

Listening wouldn't be too bad -- watching is another matter entirely!

If the plan has not restated, (and it appears likely that it will not restate) are the balances eligible for rollover?

Your compensation definition should help. Also look for a definition of the limitation year. It is usually right by the definition of plan year.

Thankfully, no!

Thanks Larry. My first job out of college was working in personal trusts. Although that particular acronym was not familiar, the concept is.

Having resigned from the case, we will not be preparing the 5500s. But the other issues you mention are enough to keep us busy.

Or that the person thought doing one disqualified them from doing the other.

Scary thing is, it did help!

No, at least we're trying very hard not be.

We do not know.

For the non-lawyers among us -- what does GRAT stand for?

Bundled service provider who has physical control of the assets. After multiple contacts over 18 or more months has a handful of clients who have ignored all attempts to get their documents restated. After more contacts explaining the need for VCP filing, service provider resigns from the cases and instructs clients to provide direction about where to move the plan assets. Notice requirements of the written service agreement were met before this resignation. No instruction about moving assets has been provided. Distribution requests from individual participants are now beginning to show up. What sort of liability issues might the service provider expect if 1) the requests are honored after resigning from the case or 2) valid requests are NOT honored because of the resignation?

Does anyone still have an account balance?

Welcome to the Hotel California -- you can check out any time you like, but you can never leave.

What if the forfeitures are a result of a correction? One of the most common errors that we see is a payroll clerk who continues making deposits for someone who has either lowered their deferral election or terminated employment. These amounts were generally deposited as fully vesting money types (deferral or safe harbor match) but must now be forfeited. The argument that they cannot be used for safe harbor contributions because they were not deposited as fully vested in the first place now becomes rather convoluted.

Thank you! Faced with a choice to follow the terms of the IRS approved document, or follow their recent Q&A I'll follow the document.