ERISA13

If a company establishes a SIMPLE IRA plan by the October 1st deadline for 2016, does that mean they would have needed to distribute the initial 60-day election period notice by August 1st?

Have any of you non-producing (non-licensed) TPAs successfully counted your experience in order to meet the 3 year experience requirement for the CFP designation? I have met the education requirement to sit for the CFP exam but do not want to waste time taking it if my experience will not count.

Thanks for the reply Lou! So in my example above, there would not be any attribution to the spouses for CG purposes since neither spouse has direct ownership? But if the ownership for Owner 1 and his spouse had been: Company A Owner 1 40% Owner 1 Spouse 20% Then, after attribution, Owner 1 would own 60% (his 40% + wife 20%) and the wife would also be deemed to own 60% (her 20% + husband 40%) for CG purposes. Is that correct?

I’m trying to get a better understanding of controlled groups. This should be a straightforward situation that I think I’ve made too complicated and confused myself. I’m trying to determine if a controlled group exists in the following situation: Company A Company B Owner 1 50% 33.33% Owner 2 50% 33.33% Owner 3 0% 33.33% -Owner 1 spouse is an employee of Company A -Owner 2 spouse is an employee of Company A -Not a community property state Based on the amounts above, the common control in Company B is less than 80% (66.66%) so no controlled group. But I’m getting confused on the attribution (if any) to the spouses. I know the spousal non-involvement exception does not apply since they are employees so would the calculation look like this? Company A Company B Owner 1 50% 33.33% Owner 2 50% 33.33% Owner 3 0% 33.33% Owner 1 Spouse 50% 33.33% Owner 2 Spouse 50% 33.33% If so, would common control in A now be 200% and 133.33% in B resulting in a controlled group?

Thanks guys! Congrats to you as well BG5150! So what's next after the CPC?

I just received my results today and I also PASSED! That was a very long eleven weeks exactly of waiting to find out the results. Now I'll get to add a few more letters after my name that nobody I work with understands

Thanks for the responses! Glad to hear the favorable experiences you all have had with FT William. I have not been able to find any reason to stay with Relius so I think we are going to join the FT William family as well. We were also concerned with losing the historical data that we have in Relius but it is my understanding that since we have our own Relius server and don't use the ASP online version we will still be able to access our prior year information in Relius. Can anyone confirm that?

I found this thread while searching for posts on FT William software and was just wondering if anyone has regretted switching from Relius to FT William. We currently have our adm, docs & 5500 software with Relius and are considering changing it all to FT William. So far we cannot see any negatives to making this change. For those of you who have made this change, are you glad you did it?

For small plans, are salary deferrals considered timely deposited as long as they are deposited to the plan within the 7 day safe harbor deadline or do the deferrals have to be allocated to the participants by the deadline? For example, for an employer who has weekly payrolls, would they be in compliance by depositing the employee deferrals into a pooled plan account each week and then allocating the deferral amounts to participants monthly, quarterly, etc.?

A small 401k plan is not sure if all the Form 5500 filings are up to date. I searched for filings on the EFAST2 website with no results. I then searched FreeErisa.com and the latest filing I found was 2001 & 2002. The Plan Sponsor does not have copies or any returns for me to look at and they were using bundled TPA services with a provider that is no longer in the business. I feel pretty confident now that 2002 was the last filing but is there a way I could be more sure since I guess the tax id could have been incorrectly entered preventing my search from locating the filings? It is my understanding that DFVCP is available for all missed filings as long as there have not been any notifications of late filings from the DOL/IRS & accordig to the Plan Sponsor there has not been. Anyone have experience correcting 10 years of late 5500s and if so any advice?

Austin - Thanks for your response! On your reply to my #2, our firm does not charge any distribution fees to the Plan. The only distribution fees that would be charged to the plan would be charged by American Funds, Hartford, etc. so wouldn't they be the one to include that in their disclosure? If the client later wanted to pay their bill using the forfeiture account would it still be a PT if we provided a 408b2 disclosure prior to the bill being paid from the forfeiture account? I agree that providing the most disclosure is the safest route but at this point I'm just trying to understand exactly what is "required" since I'm only 2 weeks away from showtime. Thanks again!

I've read through the previous posts on this thread and wanted to see if I am understanding our situation correctly......any guidance is appreciated! We are a CPA firm that provides TPA services for a few plans. For the majority of our plans, the Plan Sponsor pays all plan related fees so we do not get paid from plan assets. We do have a few plans (with American Funds, Hartford, etc.) that we receive revenue sharing payments for which I understand makes us a Category 3 CSP for those plans. It is my understanding that: 1. For the plans we provide TPA services for where the Plan Sponsor pays our fees directly with no fees being paid from plan assets, we have no required 408b2 disclosures to make. 2. For the plans we receive revenue sharing payments on, we will only be required to disclose the revenue sharing payment information since all other fees are paid directly by the Plan Sponsor. Am I understanding things the same as you? Thanks!!

Thanks for the response Hiatus. Anyone else run into this situation before?

I took the ERPA exams and found they were much easier than I expected. I've been working with retirement plans for about 4 years but immediately started working on ASPPA designations when I got into the business. I had already passed all the ASPPA exams needed for the QKA and QPA before taking the ERPA. I just printed out the ERPA exam outlines that listed what would be tested and then reviewd those topics in the ASPPA textbooks I already had. That worked for me. In fact, after taking and passing the ERPA exams I was suprised that ASPPA automaticaly awards an ERPA with a QPA designation because in my opinion the DC-3 and DB exams required for the QPA are much more difficult than the ERPA exams. Good luck!

We have a client in an Affiliated Service Group (A-org). The A-org sponsors a SEP IRA that covers the 2 employees of the A-org and the FSO sponsors a traditional 401K (ADP test) that covers the 50 employees of the FSO. Thanks to Derrin Watson's Who's the Employer, I believe I understand correctly that members of an Affiliated Service Group can sponsor different plans with different levels of benefits as long as they can pass covergae testing separately (but must include employees of all ASG members in testing). But how would this work when there is a SEP and 401K? Does a SEP even test coverage or is it just required that any employee of all employers in ASG that meet the SEP's eligibility requirements receive a SEP contribution? Can you aggregate a SEP and 401K for coverage or nondiscrimination testing? If so, how would that work? I don't work with SEP's or Affiliated Service Group very often so I appreciate any guidance you can give.