Bill Presson

Concur

If I remember correctly Mid Atlantic used to do something like this in conjunction with TPA firms that did in house daily val.

We've got offices in Orange County and in San Diego. Any preference? I'll ask them when I know.

Back in the days when I worked with a couple of firms that did inhouse daily valuation recordkeeping, we filed all our plans on a cash basis. It's very common. WCP

We use the FTW volume submitter document that is in an AA and BPD format. Section 7.08 in the BPD outlines what needs to happen if there is a missing payee. You can also enlist the services of Penchecks or Millennium Trust or others is missing participant searches.

Sounds vaguely familiar... ?

I believe it to be technically possible, but not recommended. Depends on whether the TPA is performing the "recordkeeping." As I said, I don't recommend it.

Luke, I agree with the conclusions, but don't agree that there isn't guidance. There is. It's in the document. It says exactly what to allocate, how to allocate, and when to allocate.

Correct.

Correct.

I avoided even opening this thread because the title looked boring. Then it kept showing up with new posts so I just now opened and read through this. I'm actually quite stunned with some of the positions taken here. My votes, FWIW: 1. If $100k is deposited to a pooled account early in a plan year, it's not allocated as a contribution until the plan says it's allocated. Generally that's the last day of the year. 2. If the $100k earns $5k, that $5k is allocated as earnings and not as additional contributions. (Occasionally, we'll have clients park this $100k in a business account outside the plan. If the $100k earns $5k in that situation AND then $105k is contributed to the plan, THEN the $105k is allocated as contributions). 3. If the $100k loses $5k, the $100k still has to be allocated as a contribution, and the loss is allocated as a loss of earnings. This is generally considered a bad thing. WCP

If it's a former employee, why isn't the former employee eligible for a distribution? Doesn't have to be called an RMD.

Typing out loud here: what if the entity that wanted to revoke safe harbor elected to spin off their portion in the plan to create a new plan and then revoked safe harbor? I assume that's possible? Then each would have to satisfy coverage testing on their own?

BG, As Luke says, the relief would have to come from Congress and who knows what they will do. Nevin posted an article today that there's a bill introduced to temporarily increase the DC contribution limits, so it seems everything is in the mix. WCP

Not sure there are exact guidelines. But during a webinar that Brian Graff was doing for us last week, I asked him this specific question. He said that the "intent" of the legislation (based on his discussions with the drafters) is that the amounts would be those attributable to that 8 week window and associated with those payrolls. If employers do differently than that, their mileage may vary. WCP

Not yet. ARA has requested it, but nothing authorized. WCP

Okay. Can't help on the deduction question, but sometimes the eligibility isn't accurate.

It's also an issue right now because the IRS center in Ogden isn't open. So depending on when they open back up, there will likely be a backlog. I can't imagine it's not easier just to grant a blanket automatic extension to 10/15/20.

First, are you sure the employee was eligible? What was the eligibility requirement? When was the employee hired?

No one wants to play "guess the right number"? ?

I don't see how someone can legally decide in 2020 to max out deferrals for a prior year.

Agreed.

Ding...ding...ding!

Congratulations! Very happy that y'all have lasted and succeeded.

The plan sponsor elects whether to allow the specific distributions. If a participant is eligible, but the plan hasn't made the election, the participant can still be eligible for the CRD tax treatment, but the participant can't force the plan to do something that isn't part of the plan.