Bill Presson

Use the employer EIN to set up the account and then update it when the TIN arrives. Been there, done that.

Our basic plan document gives the Plan Administrator the ability to decide in its discretion whether to accept a rollover of a loan note.

Jak, For what it’s worth, I wouldn’t try to do this ala carte. He needs three full valuations and everything that goes with them. Then add the late filing work. That will get you where you need to be.

And post the response here. 😇

We do a lot of owner only plans. We also charge a lot to correct errors when we take over the plans.

Of course you can do SHNEC each year but you do have to do an amendment. As you note, you can amend to 3% by 11/30. If you want the next year to start off NOT a SH, just include that in the 3% amendment by saying it’s only for XXXX year. So one amendment per year. Now I think that’s a real PITA but it can be done. Participants might not like it so much.

Peter, you would probably run afoul of the 401(a)(26) minimum participation rules.

Does the plan allow for in service distributions at all?

Each Roth conversion in a qualified plan has its own 5 year clock. It does not work like a Roth IRA.

Peter, you think the service agreement allowed the TPA to ignore the regs and documents?

As Peter suggested, the current TPA is wrong.

I’m confused by the 11/1/24 date mentioned for the 5500. What does that mean?

Of course.

We've already gotten one for 2025 plan year. Very odd.

FWIW, I would look to find a new RK.