JKW

I agree with you Mike - I think b/c it says 'at least'- it can't be assumed to restart.

I have a question for top heavy determination. I have a plan in which an owner gave up ownership as of 12/31/14. So when using the 12/31/14 balances to determine the 2015 top heavy, he is still being included. Is this correct?

Hi. The document does not discuss restarting . The form states "I agree to suspend my payroll deductions as set forth in condition #3. Condition 3 states " I must suspend my contributions to the Plan for 6 months after receipt of my hardship distribution". Thoughts?

Hello. A participant took a hardship in 2014 and the deferrals were suspended. Who's responsibility is it to restart deferrals after the hardship? Its not stated in any procedures the plan sponsor keeps. In this case, the plan did not restart after 6 months.

Thank you.

I have plans that payout participants with under 1000.00 for the automatic cash out provision. Lately it seems several participant don't cash the checks or the check is returned due to the address being no longer valid. Usually these checks are under 200.00. What are other administrators doing with these checks? For a plan to use extensive steps to try to locate the missing participant - it seems expensive for such a small balance. And we don't want to put them back in the plan. Before rolling them to an IRA using the last know address - anything else we should consider? Thanks for any guidance.

I have a plan that has had an independent audit done over several years but is now under the 100 participant rule. Can the plan just switch to the 5500-SF now that the beginning number is under 100? Or is there anything else to consider? Thanks.

I have a plan that excludes bonus and should not have withheld on a bonus payroll but they did and submitted the 401k and match for a few participants. Since this money does not belong in the plan and the 2015 books have closed distributions for the excess amount have to be distributed and match forfeited. What 1099 code should be used?

Because no one worked prevailing wage jobs.

That is what I thought. The software is giving an error - assuming a final return b/c there are no assets and no participants at year end.

I have a money purchase plan that was effective on 1/1/14. They ended up without prevailing wages in 2014 so they did not fund the plan. Do I still file a 5500 with 0 dollars and 0 active and total participants? Thanks.

I have a plan that had missed deferral opportunity corrections done for the 2014 plan year (they made the 50% correction and lost earnings). The participants deferral was not set up timely on payroll. Should the amounts be reported on the 5500? Or no because its not as if they were withheld and not submitted. What's the best way to do this?

They just didn't send it in on time.

Yes - deferral changes only semi-annual. Can stop any time but changes only semi-annual.

The plan only has semi annual changes.

I was just wondering what common practice was when a participant hands their enrollment form in a week or so after the plan entry and misses the first payroll run. For example a plan has a 7/1 enrollment first payroll is 7/7. The participant didn't hand in the enrollment form until 7/10 so the contribution deferral was not established until the 2nd payroll run. Does the participant just start from the 2nd payroll run, are the employees told "too bad wait until the next enrollment", or double up on the deferral for the 2nd payroll? Wondering how other admins handle this. Thanks.

Thanks for your quick response.

I have received a QDRO for a plan participant where the spouse receives a flat dollar amount as of 12/31/14. Typically qdro's will have a section on earnings stating the alternate payee is eligible for earnings from 12/31/14 to date of segregation. This qdro does not address earnings during this period. Only stating that after the account is segregated the alternate payee is entitled to investment earnings. Any thoughts on how to handle the period from 12/31 to current date?

Thanks.

I have a plan that has a current set match. They would like to add an additional disc match with a vesting schedule. I have never had this come up. Is this possible?

Ok, so even if over 70.5, if someone works during the year and dies or retires in 2014, their RBD isn't until 4/1/15. Thanks for the clarifications.

Esop guy- I completely agree that the 2015 rmd should be done before moving over. I just want to carify - he wasn't 70.5 in 2014, he was 73, it was just that he was active so didn't plan on taking the rmd for 2014. So is it still by 4/1/15? So, the 2014 RMD would be done before 4/1/15, then the 2015 RMD, then rollover to inherited IRA.

I have a participant who was over 70.5 and still working in 2014 so did not plan on taking an RMD. He passed away in 2014 with children as the beneficiaries. The accounts will be split into inherited IRAs. The bene's did not complete the beneficiary paperwork until 12/31/14,not leaving enough time to make any transactions in 2014. My 1st question is - since an RMD was not taken in 2014, do they need to take one in 2015 for the 2014 amount before moving the account to an inherited IRA? Secondly will they need to take 2015 distributions of their own calculated in their individual accounts?

Perfect. Thanks.

We have a plan that is closing down and there is a deceased participant with $250.00. We have tried to locate his listed beneficiary with no luck. Any thoughts on how to handle this?