Bill Presson

Redcloud, you better take Peter up on this.

Did you not get my text? Or did you not want to use that one?

Whatever the new name is. The critical pieces the IRS/DOL need are the plan number and the EIN

Wrong track. Just file a single 5500 for 2020. Put the new sponsor info in section 2 on the first page. Put the old sponsor info in section 4 on the first page. (I'm assuming this is an SF, I didn't look at the regular 5500).

Agree with BG.

What does the document actually say? Most say something like "as soon as administratively feasible" following termination of employment. So if it's not administratively feasible to pay her until the 2020 is done, then tell the employer to tell her to wait. Someone has to be willing to take a little heat here and not cave.

Saying it and getting it done are two different things. 😁

The only issue I see is that it has to start tomorrow if it's a 2021 calendar year plan.

I don't think there's a conflict of interest. But there might be concern about disclosure at home (ie pillow talk) and it would be a good idea (IMHO) to disclose it up front and let your client know that it's not uncommon for those relationships to exist and that nobody ever gets information on anyone.

Pretty sure he was teasing.

Did you submit the Form 14704 with everything?

Agree with Mike. Require the owner hire an ERISA attorney or walk away.

Correct, much like an excluded class.

If it's a valid waiver, they are not a participant in the plan.

Yes. It's a legitimate plan expense.

Does SECURE allow you to use the business extension for starting a new plan if the business tax year and the plan tax year don't match?

As long as the EIN and plan number are correct, I wouldn't lose sleep whichever way you do it.

Occasionally greater truths are learned on this board.

Depends on the document, though she would usually immediately re-enter. So, RTFD.

Generally you would look at the fund(s) the money was previously invested in.

This is all correct. But, to me anyway, this is the investment advisors job and not the TPA's. All the annuity options galore can be illustrated and explained and sold by the investment advisors. But, because the requirement will end up on the plan, it will slide to us to implement. Exhausting.

Employer should find a way to help this employee outside the plan.

He should have a deferral election form completed

FIS provides updates to the DC termination package all the time. It's available on their website. Use that and you should be good. If you're not sure, you can ask them and they'll help.

Well, that may complicate things. I believe it was an error to not match the amortization to the pay date as that's when the money is actually available. I think Bird is right here.