Bill Presson

I don't see this as a late deferral issue. But why is the record keeper only doing one trade a week?

Voila!

Larry, Click on your name next to your post. It will go to the window allowing you to edit your profile. Near the top right, you'll see a small version of your name and avatar with a down carat. Click the carat and then click Account Settings. The Signature option is on there. Might be an easier way to get there, but I haven't found it.

Gotcha. Didn't see that in your first post anywhere. Sorry, ESOPs aren't my thing.

All of this is generally irrelevant because we now have approved documents that allows for each participant to be in their own group.

I've tried to stay anonymous on a message board once. Just felt like I couldn't say what I needed to and keep it that way. So, from then on, I've always either used my real name or made it pretty easy to know. As to making a change, you can go to Edit Profile and change your Member Title to anything you wish. It could be your real name or like what I've done. You could also add it to your signature. Neither of those things require any board changes.

I would politely decline. Engaging a consulting firm to provide a service isn't the same as purchasing a product.

No, I don't work alone. We have 80 employees, including 6 enrolled actuaries and some of the most experienced people I've ever had the privilege to work with. But I still like getting others input on my questions and seeing different perspectives on questions we may have never run across. In addition, this (to me) is the updated reincarnation of the old PIX message board. I learned lessons there and made lifelong friends. It's nice to be able to continue that.

For the first year, it's true that they need to adopt the plan by the end of the year. But if they are so worried about the number, they likely aren't making enough to have a plan. As to amending the formula, that needs to be done early in the year before earning the right to the accrual and I wouldn't recommend that be done too often. It's just possible they aren't a good client.

Yet another example of why deferrals should never be done by check. These clients kill me.

D Lewis is correct. When you renewed in 2017, you had to show your CE for the period ending 12/31/16. Your next renewal period is the subsequent three calendar years.

Oh, please don't. Not sure I would want to defend intentionally doing it. But I like keeping it in my back pocket in case I ever need it.

I fully agree that this is the intent of the rules. But I've heard some people much smarter than me say it actually allows the former.

Peter's post was a bit of an eye opener to me. I wouldn't have thought it possible. If you use FTW, I would reach out to Brian Furgala, their new ERISA director, and ask for guidance.

File under DFVC before he gets a letter from the DOL.

Because of multiple acquisitions over the past few years, we seem to be paying almost every document provider out there. We're working to reduce that. Anyway, we heard the same on the FTW document. Just got an email from Accudraft that they got their approval letters and expect the updated documents to be available June 1.

I would be shocked if a standardized prototype could be used. I wouldn't even think a volume submitter would work without significant modification. Looking forward to what others say.

I've seen documents give this option when choosing 1 year of eligibility. It will ask if you want employees to wait until the entire 12 months of the year is satisfied or make them eligible upon completion of the 1000 hours. I would never intentionally choose the latter. Just because it's legal doesn't make it sane.

There are a number of providers out there that can assist with this as well: Millennium Trust and Penchecks, just to name a couple.

Wow.

I'm guessing the hours are just wrong unless s/he really did nothing in the business.

So, let's discuss for a moment. Assuming all the dates for the OP are 2017. Rhoda is hired on Feb 15 and enters the plan on 6/1, then the eligibility is changed in September 2017 to requirements that she does not meet. Now to discuss things that aren't presented by the OP. 1. Let's assume it's a safe harbor non elective plan (and ignoring all the safe harbor amendment requirements for the moment). Would she get a 2017 contribution? I would say yes. 2. Let's assume it's a regular 401(k) and she starts deferring on 6/1. She's a participant at that point but in September would move to an ineligible category, correct? But she's still a participant for the 5500 count. 3. Let's assume it's a regular 401(k) and she doesn't start deferring on 6/1. She's initially a participant, but in September would move to an ineligible category and then WOULDN'T be a participant for the 5500 count, correct?

So you're saying she already entered the plan on 6/1 and then three months later the eligibility requirements are changed? Now, I know you can change a category of eligibility that would impact a participant, like excluding a division prospectively. But I"m pretty sure you can't change the eligibility for someone already in the plan. I'll see if i can find something on that.

So when they get "chunks", are they paying it out as w-2 income? Or are they self employed and just getting a draw? Because their actual income then wouldn't be determined until much later.

That's kind of a big deal that she missed that.