Bill Presson

Even if the computer system allows it to be filed, the DOL can still reject the filing. I think it's a risk, but I guess you can try. What the CPA is suggesting used to be done often prior to electronic filing. I would be more likely to just not file and do a DFVC later.

Thanks. I shutdown my computer every night, so I don't think it's that. But I'll keep looking. WCP

I love being able to click the little button/bullet and go directly to the first unread message in a thread instead of having to scroll through all the ones I've already read. However, about a week ago (or so), I noticed that when I do that, I can only read whatever message shows up on the screen in the thread. There is no ability to scroll down through the rest of the thread. I've tried using the keyboard page down and arrow keys. I also tried the scroll button on the mouse and "grabbing" the scroll bar on the right side of the screen. Anyone else??

Mike, George said the death benefit isn't an asset until paid by the insurance company. Am I misunderstanding your answer? WCP

Thanks, GMK. That was the item I was missing.

https://epic.org/privacy/rfpa See if that gives you anything. PS: no idea how to post a link on here anymore. Glad that was a short one so I typed it. I've tried to use the "link" icon on the menu several times, but I'm not smart enough to figure it out anymore.

Also, most firms have published privacy policies. Was the sharing in violation of your privacy policy?

The instructions specifically exclude payments directly from the plan sponsor that are not reimbursed from the plan. The auditor is wrong. WCP

Thanks guys. They're using Relius to do the calculation and I believe it was accurate. Just thought it might be nice for a double check outside the system.

Mike/Tom, Just saw this thread and haven't opened the spreadsheet yet. What are the odds it would work for a 140 partner LLC? WCP

Just an FYI, rollovers aren't considered contributions when performing the incidental test.

To do a simple 5500 for one year might not be much of a burden. But what about the intervening years? And the DOL/IRS correspondence that would result? No telling what kind of black hole that might be.

If the plan doesn't allow loans, then the participant can't borrow from the plan. The insurance policy is an asset of the plan so it's covered under that rule. The insurance loan provision would allow the trustees to borrow money out of the insurance policy and put it in the participants "cash" account to invest.

Sign a new document.

Charles, remember that you will have to get a CPA firm to agree to whatever audit adjustments are decided upon. Just because the CAO says something doesn't mean a CPA firm will agree that it meets AICPA standards. And they will likely want some kind of indemnification.

If you missed it, so did I. And I don't think we both did.

There was an update to the EPCRS this year that covered this. I think it's Rev Proc 2015-27.

I haven't seen it on 401(k) plans, but I've seen employers do it on health insurance. Since they have monthly premiums, they want the 24 pay periods so it matches up. The two pay periods they skip are for the two months that have three pay dates each year. I would be uncomfortable to do it if someone has chosen a percentage though. Just thinking out loud.

We generally just provide a summary of the test results (ADP/ACP, 416, 415, a(4), etc) and don't provide the backup. In the rare situation where a client wants to see it, we've provided it, but it's not a standard.

Our parent firm, Warren Averett, does 200+ EB audits per year. I just spoke with our audit partner and he said that about 5% of them are unqualified and the rest are disclaimer (because of the limited scope). He said he didn't recall issuing a qualified opinion and in all the discussions they've had with the DOL that would likely generate a pretty quick contact from EBSA. FWIW.

I really think it depends on what the paperwork that was signed says. If it says it's an IRA account, I think you're out of luck.

It's a lot like wedding vows.

I have an idea what you're talking about, but I'm not gonna guess. You'll need to provide more details. Please be specific and describe the entire situation.

No.

This is how we've always done it. Treat it like a transfer into a "fund" and then post a gain/loss to get back to the ending cash value.