Bill Presson

without looking at anything, i'm pretty sure that's not kosher. But they could still adopt a PS plan for 2020 and merge it into the 401(k) plan in 2021.

None of us understand who is getting the PPP money, who is the PC, who is the employer, who is the plan sponsor and who is reimbursing whom for what. It just doesn't make any sense. Way to many players it seems.

You still need a plan with individual groups in order to vary the contribution by person.

When did the common ownership occur? Does the 15% owner of Company B work for Company B?

We aren't charging a restatement fee for any client that hired us in the past year.

Why would the "client" receive PPP money and not his PC?? Is the client also an employer? This is still confusing.

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.