Bill Presson

I got my QPA way back in 1991. I did go back and get my QKA (I think there was an extra exam needed for it at the time).

The actual definition will be in the basic plan document.

From the QPA credential guide: To obtain the QPA™ credential individuals must: Have earned the QKC credential Pass the QPA™ exam Agree to abide by the ARA Code of Professional Conduct Apply for the credential

It all depends on what the QDRO says.

Surrender the excess insurance.

Also, what if the owner did an inservice distribution the year before the termination and filing? You probably wouldn’t think twice about it. Just make sure you have documentation of the bankruptcy and $0 assets. Might be worth completing distribution forms rolling the $0 to an IRA just in case anything shows up in a year or two.

Participants may have the ability to make trades in accounts but they aren’t the “owner” of the account, the trustees are. The trustees have the ability to liquidate whatever account they want. If they haven’t done so, it’s on them.

Are you saying that (in your example), the QACA contribution for 2025 has a 2 year vesting schedule and the QACA contribution for 2026 has a separate 2 year vesting schedule? Because if you are, that’s wrong and vesting like that hasn’t been allowed since the 80’s.

I agree with every word of this except “sorry.”

1. You need an atty not us. 2. I’m not an expert but I’m pretty sure a QDRO isn’t required to be used to split an IRA.

Assuming it’s a PS source failure, usually it’s an -11g amendment OR the plan document has specific methods the plan has to follow.

I’m never surprised if a DRO is kicked back once. I’m always surprised if the drafting party causes one to get kicked back twice.

Of course and I don't have any issue with it. Just pointing out that FTW aren't sitting around for a month before going to the Treasury Dept.

😂

Not to defend Nationwide or your credit union, but federal taxes withheld have to be deposited pretty rapidly. Roughly speaking, if an entity had more than $50,000 withheld in 2022, they are a semiweekly depositor in 2024. Pretty sure Nationwide would hit that standard. So they're depositing all withholdings with the IRS twice a week.

Agree with Cuse. This might be helpful. https://www.napa-net.org/news-info/daily-news/case-week-qualified-separate-line-business

I would still recommend meeting the tax deduction rules for the IRS.

I’m not so sure. Even if it’s w-2 wages, an owner only plan isn’t subject to Title 1 of ERISA and that’s what drives the DOL.

https://www.irs.gov/retirement-plans/self-employed-individuals-calculating-your-own-retirement-plan-contribution-and-deduction

Best of luck, Ms Lisa!

Ms Lisa, you're wasting your time unless you get a lawyer. Find one in your area (nearest big city) that is familiar with ERISA QDROs.

Interesting: https://benefitslink.com/boards/topic/52525-merger-of-safe-harbor-plan-to-non-safe-harbor/

Controlled group attribution falls under Section 1563. For that an adult child’s interest is attributed to the parent only if the parent owns MORE than 50%. Same issue in reverse. So they need to be careful that the dad never add any ownership.

Well I would think they have to make the final contribution so everything else is moot.

Don’t try to fight the bank, just move the money. It’s not worth the risk.