K2retire

Unfortunately, they're also very common.

I've heard (but not yet tested it) that some signers are getting error messages if they fail to login on the DOL site after they register. Somehow that supposedly prevents them from gaining access through the 3rd party software. That doesn't make sense to me. Has anyone else experienced that?

There should be another blank at the end of that sentence that specifies if the match is made per payroll period, monthly, quarterly, for the Plan Year or some other choice. That is what determines whether or not you have a true up.

Or the TPA might have asked all the right questions and the client chose to give incomplete answers!

It is a lot of work and hassle. But so is explaining to an auditor why plan benefits were paid back to the company which is what your paper trail would show otherwise.

Shouldn't this letter come from the Plan Administrator? As an investment company recordkeeper, we require the signature of the trustee because that is who is our client. We make the check out however the trustee directs and send it to the plan administrator to record and distribute.

And although the step father's ownership is attributed to the mother, it is not attributed as second time from her to her son.

Not to mention that the same could be done with any check you've ever written, or letter you've signed, or any other document containing your signature. As a recent victim of identity theft, I can say that the theives didn't need my signature to set up bank accounts online.

The plan exists -- but there are no assets to report on a 5500. They are different issues.

If the employer doesn't happen to have a payroll that falls on 12-31, the final check of the year would be the last one considered for that calendar year. The first check in January is all counted in the next year. That is the same as how it is reported on the W-2s for the year.

The document should specify if the match is made per pay period (no true up), per plan year (requires true up) or some other choice.

Because this industry is such a small part of what my company does, I'm not sure this is an apples to apples comparison. Our 2009 raises were delayed by 6 months and about half of the previously typical percentage. This year we are told the same will be true, despite restatement fee income and a company wide lay off earlier in the year.

This is a case of 2 unrelated employers. If I'm understanding you correctly, it is that fact that prevents the distribution until there is some other distributable event. If it was one plan, or two plans of related employers, the potential disqualification of the plan would allow the distribution now.

The ERISA Outline Book includes a reminder that excess deferrals not refunded by April 15 require some other distributable event to be paid out. The EPCRS correction says it is for the excess to be distributed, but doesn't mention waiting for a distributable event. For a client who called after April 15 saying they just learned of the excess, what does one advise about timing of the distribution?

I've had many DBs that accepted rollovers from DC plans. We often set up a bogus plan in Relius Administration solely for the purpose of tracking the rollover accounts in a DB plan. Because our clients had pooled investments it was a real pain.

And does anyone really believe that all participants will be able to come up the appropriate documentation 2 or 3 years later, especially when they've long since changed jobs?

If the profit sharing plan includes 401(k) provisions and a Roth option it should be no problem.

No, it's IRS logic!

Be careful about no related parties. We had a dentist who was loaning money to his patients from his plan. Since the loans corresponded to the amount they owed for dental services, the IRS was not amused.

A great option if the employer is not concerned about the termination triggering 100% vesting.

Additional suggested choices: Computers run amok Poor training of staff Masochism All of the Above!

Have them start by asking that question of the person or firm who wrote the 401(k) plan document for them.

But hey, we can now file on the 2009 form.

I agree that it is rare -- but you still have to check the document.

Why not simply restate the MPP as a PS?