Bill Presson

I can't find what I'm looking for, but aren't terminating plans required to roll force outs (unresponsive participants) over to another plan sponsored by the employer (or within the controlled group, if applicable)?

Sometimes this site provides bonus features not advertised!

All seems odd, especially the first one. The others may just be in there to see if you would catch it. Back to item 1, any chance they gave you a 3(21) contract in error?

Thanks. Fuzzy memory.

Peter, doesn't Florida still have a "document stamp" or some such tax on the books?

But you could do an -11g for 2020.

I would start here. It was their error (assuming your post is accurate) and the liability should be theirs. Start the negotiations with them paying for VCP.

Well, we know a voluntary amendment fee (for a change in eligibility, etc) is a settlor cost. So a change in recordkeeper (since it's voluntary), I would say we start with "no" as the answer. But if the sponsor and trustee document that it's a good fiduciary decision and in the best interest of the participants, I think the case could be made that it's a valid expense.

If it's the current required restatement, then the plan can pay the cost.

I add it like a wet signature, not docusign.

We use it. I sign IRS forms all the time and have never had an issue.

Yeah, I don't see anything there that would allow terminated participant accounts to be kept from receiving earnings.

There is a section in that document that specifically says how the earnings are allocated. I would find it very odd (likely impossible) for a plan to allow this.

Pretty sure the adult children make the plan subject to Title I and that requires a bond.

Congratulations David! Enjoy!

Dangit, you're right on the in-service as of a date. Probably should have focused on the amount. I still think that's accurate.

While the definition is an issue, this is an example of why I never want the plan to specify the fail-safe correction. I would much prefer to have all options available and do an -11g amendment to correct.

It's not a cutback. Those benefits aren't protected benefits. I think you could go as high as $1,000 (which I always recommend) or could eliminate them altogether.

If you are doing a single filing because you have 1 plan with multiple benefits, that gets you to the missed schedule A. I can't imagine having a wrap plan document that still requires multiple 5500 filings.

I can't fathom the person authorizing or writing the corporate check actually thinking they're doing the right thing.

Yes, they have to make a top heavy contribution for 2020. Why would their 2019 status impact 2020? Seems like a bad decision to eliminate the safe harbor. Might want to consider the retro safe harbor if there are also testing issues.

Probably through ETFs, but likely not directly.

I find this incredibly difficult to believe.

No.

You may also have an action against your divorce attorney if they didn't find out about this. A pension is pretty hard to hide in a divorce.