Bill Presson

I'm a bit confused. If service prior to meeting eligibility didn't count towards eligibility, how would one ever become eligible?

Awful lot of work for a $7,000 contribution. Any way you can convince them to not do it?

You can request it from the participant (and should) but you likely will not get it.

We get copies of all statements as well. We review every single transaction related to cash flow in or out of the accounts. We don't exactly calculate the unrealized gain/loss like we used to because the forms (for small plans) don't require it anymore. We don't have any balance forward clients that are audited. We have also had brokers ignore the rules and pay out a participant without us knowing and we've had to file 1099's during the summer for distributions the prior year. But I don't have a lot of sympathy with the TPA not catching it during the trust accounting. Now if the client was supposed to complete the trust accounting and provide that to you, then it's not your problem to begin with. It's the client's. Just keep that in mind and recommend the appropriate corrective action with the appropriate corrective fees.

You keep saying "takes a distribution" and "keeps the funds in the plan" These, in my mind, are not compatible with each other.

I think you have it pretty well laid out.

We use Relius for admin and Ft. William for documents and 5500s.

If the employer wants to "correct" it, that's great. But while I see a small technical issue here, I don't really see how the participant is harmed. Especially if they took 2 years to raise the issue.

Agree with QDROphile. We've had this happen several times over the years with our own company as we've merged with other accounting firms.

Yes, unless it's purchased out of the plan first.

No, I think the read receipt is perfectly fine and I'm not even worried enough to use the read receipt for a firm that provides everyone with a computer.

Meaning that, if the compensation starts or ends up below $255,000, the entire calculation is circular. If the DB amount changes, then the comp changes which changes the DC amount which changes the comp amount, etc, etc.

You could also use a product like ShareFile that is a secure delivery method. We use it for delivering large files or files with confidential information, but it has a method of showing everyone that actually downloads the file.

Don't overlook the fact that it's only $217 though. It might really be worth your while to send her a check as long as she signs a "hold harmless" instead of getting into a letter duel.

Did he add FOS to the end? I think we just all assumed that credential!

My favorite card ever was one I got from an insurance company actuary I met. It had his name listed and then "FCA, ASA, EA, MAAA, CEBS, FLMI, CLU" and right before he handed it to me, he took a pen and wrote ", ChFC" at the end. BTW, I know this because I got the card in 1985 and I still have it in my desk.

If it's part of a trailing dividend or a final contribution posting (which we really try to avoid), we will not charge a fee, but we do charge the hard costs (check, etc) for the additional distribution.

I have QPA & QKA now and just waiting on the IRS to approve the ERPA application. I'm thinking about spelling out Enrolled Retirement Plan Agent under my name and just have the other letters after. I understand Andy's thoughts, but the initials, etc aren't really for clients. They are for potential clients. It tends to provide them with some initial comfort that allows me the time to provide confirmation of expertise.

I never like spam, but it was good to see the original post again.

We have always used check date. So if a participant enters 4/1, they would complete the deferral election form and the amount would be deducted from the 4/2 check. If it's paid on 4/2, it's not March pay. Just like if it's paid on 1/2/13, it's not 2012 pay.

Most of the plans we handle are daily and we do the recordkeeping in house. So, our standard procedure is for the processor to determine if forfeitures are available and verify that forefeitures can be used for fees.

As with the others, I think you probably have some flexibility. But I wouldn't want to explain why I charged an RK fee to the participants and then reallocated forfeitures. It might not make any difference, but if the RK fee is allocated differently than the forfeitures, you would have some people paying more than they should have. If the fees are paid by the sponsor, then the whole question is irrelevant.

IRS letter does not disqualify them, but a DOL letter does. With that said, act quickly to file and then immediately respond to the IRS.

We've had very few plans want a Roth provision at all and those that do offer it, very few participants are using it. I've never seen it as a good option, so maybe that's influencing our clients. Also, I'm going to do my absolute best to prevent any of our plans from doing in plan conversions. That is a huge potential bucket of worms that I don't want any part of.

As MoJo said, the employer and the trustee are obligated to provide appropriate options. Now, it doesn't have to be employee directed, etc., but they can't just throw up their hands and give up. Looks like you're going to need to find a new provider. Your best bet will probably be to find a provider that will take them all so you can work with them at the same time.