Bill Presson

You're going to need to be more specific. Who's contributing for whom? Etc.

Correct.

Correct. You're golden as long as the client hasn't received a late notice from the DOL.

And, such a silly answer it is. So easy to just provide a blanket extension.

Just change with the next filing. Document the change in your notes and with the client (like in a cover letter) along with the reasons why. I like these guy's summary of the reasons: https://www.retirementplanners.com/post/the-right-way-to-file-the-form-5500 I've seen this change done (and vice versa) once for plans and never heard of any issues. I don't think you will either.

I think that's not how the ACP test works.

It would likely be more accurate than some data we get from employers.

There is no minimum and it's quite ridiculous.

This is a good example of why I've always been opposed to rehiring anyone at any time. 😁

Whose attorney are you going to contact? If it's the employer/plan attorney, then that's a good start. If it's the attorney for the AP, I don't think that's a good idea unless you get your client's permission first.

I was involved in a lot of new insurance policies bought by plans back in the 80's. The idea was to use the plan money to pay premiums for the first few years when the internal cash buildup was very low, then the participant (or more typically a trust) would buy the policy out and fund it going forward. I've never seen a policy sold TO the plan after having been in existence for years. It may be what the client wants to do, but clients are often wrong or misguided.

Jim Holland says the page numbers will show up when it's published in the IRB but will not start at one. WCP

This is correct. The owner and beneficiary of the policy is supposed to be the plan. The plan then pays out the benefit.

I'm sure the employer replaced it within a "short" time. But I've known of a client that had this issue and the advisor did something relatively similar. Because the BD wasn't going to risk having to "float" a loan for the money if it bounced. So deposit and wait for it to clear and then buy the investments.

Agree that if it's in the plan it's not a late deposit issue. But it is then a fiduciary issue. Not sure that's necessarily on the broker/advisor. Sounds like they've gotten bad checks from the employer before and this is their answer. I think that's defensible. But that makes it an employer/owner fiduciary issue.

So QSLOB is out just because of size. Now you would have to test each BRF and see if they pass. It can work, but will need to decide if the trouble is worth it.

Need more information. It will depend on the eligibility of each, the HCE/NHCE makeup of each, etc. There's nothing that says they can't have separate plans, just that they need to be tested together. And if they're large enough, they might even qualify for QSLOB treatment.

Understood.

I thought he disagreed with something. He's just leaning on you for free research and tax advice.

What is the CPA's position on this?

I agree with this. And I'm not kidding.

Are you looking for someone to handle the actual TPA administration (compliance testing, contribution calculations, annual reporting, etc) or someone to strike a daily price for a unique portfolio (similar to a collective trust account)?

Adopt a plan for 2020? Absolutely. His caveat was related to the benefit accrual formula part of the discussion.

Why do they have deferred vested benefits if they're still employed?

I don't really care too much either way, but using the same password for more than one account any more is very silly. Use software like Lastpass and have a single, very complex password for everything. And use two factor authentication when available. Then the user id won't matter much.