Bill Presson

If elected in the AA, the QACA SH (match or nonelective) can have a vesting schedule attached.

Well, the accountant should do these 6 as well. But if they won’t MT likely will.

I don’t understand what you mean the owners are going to do. Seems off. But if you’re asking about an amendment to terminate and bring the plan up to date with all legislation, yes. And an SMM is required as well.

If the money left the plan and went to rollover IRAs, someone needs to generate a 1099. Who did the 1099s for all the rest of the participants? They would likely do these 6 as well.

I’m not aware of anything that changes the distributable characteristics of the money source due to a Roth conversion. Someone needs to cite a source.

Then seems like 2 and 1 to me.

If they both have money in the plan and are both still employed, it’s 2 and 2.

Side note: $5k gain in 7-8 years? Yikes!

No.

I think it’s for terminated participants taking a distribution but not waiving annuity payment.

I can’t believe Fidelity would do that even if they could do that.

We encourage all of our clients to default to 10% MAE and probably 98% of them agree. We've had very little pushback.

Seems like the facts changed between your two messages.

What testing would cause a refund to the HCE if the plan is safe harbor?

Ms Emily, I don’t have the stats only opinions. 1. SHNE likely doesn’t offer the same incentive as SHM. 2. People shouldn’t need an incentive to help themselves. 3. We have to design plans to accomplish what the owners need as well. 4. Congress (and IRS) made the rules. We just have to live with them. 5. I wish Congress (and IRS) would stop changing the blanking rules so often.

We write it in our document that HCEs are excluded from SHNE but the employer has the option to contribute. It’s not an employee decision. Just gives the employer a lower floor when they want to do the absolute minimum. So you’ll have to RTFD.

Safe harbor match doesn't impact the ACP test of after-tax money.

They can in our ASC document.

So I’m assuming the check was written and cashed in 2025. Seems it would be a 2025 1099.

When did the assets leave the plan?

What a perfect example of govt incompetence.

Hire a professional to fix it for you. Way less than $150,000.

We had an incredibly difficult time with them last year. They were requiring medallion guarantees, etc. Client finally opened an account at a local bank and the trustee was able to go online and request a wire to an account "with the same name". Paid everyone out from that account.

Agree with this. I don’t think it’s a thing. You just don’t post the notice for the upcoming year.

One thing in our basic plan document indicates "The Employer may collect Participants' After-Tax Employee Contributions using payroll reduction or other collection procedures." So, I think the check gets written to the Employer and the Employer deposits it in the plan? Although they could have it written directly to the plan.