Pam S.

In our firm, we asked the person in our office that prepares the 945 to obtain a PTIN. This person handle all aspects of the distribution process, so it seemed to make sense that she'd be the one that'd need the PTIN. Hope that helps.

I am in a similar situation and would appreciate any feedback. A client of ours is converting their 401k plan from ADP over to another recordkeeper and moving their payroll services at the same time (though i do not believe ADP has been informed of the payroll service change yet). ADP has informed them that the earliest they'd be able to transfer the plan's assets is September 30th. No problem - plenty of time to get blackout notices out, etc. The client processes payroll weekly. ADP indicated that they would cease processing 401k withholdings with the September 17th pay period. The new payroll company will not start doing payroll processing until October 1st. Therefore, it appears that there will be two weeks where no deferrals will be withheld. The client, and I, wonder if this is an issue if participants have an election to have 10% (for example) withheld on an annual basis from their pay - it won't be a full 10% if these two pay periods are skipped. So, we thought sending a notice to the employees explaining the situation, that there would be 2 weeks where no deferrals would occur, and if they wanted to make any adjustments to their deferral election to accommodate this conversion, they would be able to do so in writing and it would be honored by the new payroll company. Does anyone see an issue with this. It just seems very fishy that ADP would stop the 401k withholdings prior to a plan transfer. What if ADP were keeping the payroll processing piece of the business - what difference would it make to the plan? Very odd...any suggestions?

To piggy back onto this question, what if the plan's assets were below $250,000? Would the client be responsible for filing a 5500 Form since they filed one to begin with (when under normal circumstances they'd be exempt from filing a 5500 EZ due to the asset thresshold)?

Thank you for your reply. I knew it must be too good to be true!

We have a client that has a 401k plan and a 403b plan. The 401k plan adp test failed and it was suggested that the refund amount be transferred to the 403b plan instead of returning it to the participant as a refund. We can't seem to find anything in the regs about whether this is a viable solution. Anyone have any thoughts about this?