Bill Presson

Why are you having to cross test an integrated profit sharing allocation?

The first computer I used in the workforce after graduating college in 1983 was a Wang (maybe a 2200) with an 8" floppy drive that we used to save some Basic programs we wrote to show some illustrations to clients. Fun stuff.

Wonder if I have a copy of Foxbase sitting around? Have you upgraded to the 3.5 inch diskettes? I think there’s 23 of them. 😇

I’m very confused by your dates. They enter the plan in June 2024. They work 1000 hours in calendar/plan year 2024. Why is the 2024 match getting deposited in January 2026?

Jak, I'm not an IRA expert by any means. However, if the beneficiary inherits the IRA and pays all the taxes, it's just after-tax cash at that point, right? How would they contribute to a Roth other than by the regular contribution rules. There's no "rollover" to do because it's not an IRA anymore.

The only things you can adopt with a retroactive amendment date is for something that is within the remedial amendment period. But the op is essentially describing a discretionary restatement so I think it’s stuck with 2025.

1. Could take an in-service distribution, if available. 2. The one challenging is likely an insurance agent that "has always done it that way".

Can't restate a plan retroactively. You can only adopt a new plan retroactively. So, you're using the other document for 2024.

This is wallowing in prohibited transaction issues and I strongly advise you to wait on the ERISA attorney.

It sucks but it happens. Two fixes 1. Refund the money to the participant in 2025 and issue a 1099r. Do not change the w-2. 2. Adopt an early entry amendment under the EPCRS self correction program and document the issue and the fix. This would leave the money in the plan.

More like "rathernotbereading" now, amirite? 😇

Kent, TLDR because Dave and Ms Lois don't pay me enough to read and answer or even figure out what the question is.

FAs can completely freeze accounts so no dividends or interest hits the account. I don’t know how it’s done but I know it can be done. So get them to acknowledge they’ve done it and explain the costs of an additional report, filing, and 1099s have to be done.

I think a public flogging of the financial advisor would be appropriate. This kind of stuff just frosts my behind.

This doesn’t sound like a mistake of fact or an erroneous deposit. This sounds like the new guy doesn’t like what some participants got in prior years. Too bad, so sad as far as I’m concerned.

Agreed.

Looking at the Rev. Rul. describes a plan where everyone has a life insurance policy but some that are provided are of different types with different types of options available for participants that might be interested in buying the policies out of the plan. I'm not aware of this having any applicability to a plan where the initial purchase of the insurance policy was done at the request and option of the participant. Plus the other things I said. 😇

Understood. We appreciate all the SDBA plans we get because you don't do them. 😇

Family/divorce attorney hopefully with some retirement experience. The first call I would suggest is to the person that handled your side of the divorce and ask him/her about the domestic relations order. It should have been handled then.

That would make me hesitate and probably use Bri's strategy of a new PS plan and then merge.

Depends on the size of the client of course. We usually would only do SDBAs for everyone if the client was smaller than 10 participants. Pooled plans can be much larger.

MizKae, I think you can contact an attorney and do any inquiry you like. And I’m no expert on governmental plans. But you said you got divorced in 2016. What spousal rights did you have in 2020? With that said, maybe you should have submitted a domestic relations order after the divorce. But you’ll need legal help for that.

I don’t agree with this. We have lots of clients using a single brokerage account per person with multiple sources. We track all of them in our system despite different vesting schedules and distribution timing. It’s not really different than having a single pooled investment with the same things. These kinds of plans have existed for a lot of years before daily valuation services were created. ETA: "not" above

I’m not a fan of different accounts for each source. The only exception I would concede is maybe Roth money.

If the transaction happened in 2023, your 410b6c transition period ended last December. Will each plan pass coverage, etc in 2025 on their own?