Bill Presson

This is what we use. We have both the DC and Cash Balance proposal online systems and are very happy with them.

There seems to be a cross confusion of several items in this thread, so I think we need to make sure we're all on the same page. tertue: 1. are you trying to calculate a contribution for the employees or the maximum deduction amount for the employer? 2. do you actually have a plan in place right now? If so, what is the plan year? 1/1-12/31 or 6/1-5/31? 3. What plan year are you doing a calculation for? Maybe this will get us headed in the right direction.

Here's what the plan says: Plan Year means each 12-consescutive month period ending on May 31 Limitation Year means: Plan Year If your Plan Year ends each May 31, are you sure the 401(k) is a calendar year plan?

This has to be one of my favorite quotes of all time. No, giving the money back doesn't solve the problem.

We use Accellion. http://www.accellion.com/ I can't speak to the cost, but we have it for the entire accounting firm 280+ people. It's an outlook plugin and is very simple to use. I've been happy with it.

Yes to the easy question. Post to participant web, email, mail to home or handout pretty much cover the options, I believe. Open to new ones.

I'm going to stick with filing directly on the EFAST2 site. Actually stunned that I can write that. But I'll be very curious to see how FT William handles a much larger clientele when dealing with service issues assuming that many Relius users switch.

I don't have an issue with the tax withholding portion. We had some pretty good legal people look at that and we did it for years. Not so sure about the other part of the money, even if its a cash distribution. And now with the new EFTP process for withholding, we're shutting it down and moving all of our balance forward distributions to Penchecks.

This is what we did. After some initial bumps, it went pretty smoothly and we're going to do the same thing again next year.

Connie, it's often called a triple stacked match or just a stacked match. If you do a search on those terms, either here or on google, you might find more info as well.

I know there is an exemption, but for the life of me I can't remember where to direct you. I've had some small community banks in the past that did the same thing and I don't recall the requirements to be terribly onerous. If my mind shakes something loose, I'll post again. Maybe someone else will remember before then.

We told them to do it, but once we submitted the electronic version successfully, our work was done.

Same here.

It generally takes us 2-3 hours.

I think it's funny that they used that number as a reason to NOT grant an extension! Well, those weren't the ones having trouble complying, dingbat, I mean, DOL!

We ended up just using the Relius IFILE extract and then uploading directly to EFAST. My assistant got credentials and she has coordinated the filings for our entire office. We still have about 25 left to actually sign, but I'm confident we'll get it done shortly. It's actually been a pretty smooth process, except for several clients that refuse to actually read our instructions.

I know that a law firm here in town does the same thing. Doesn't really speak to whether it's legal or not.

1. Hope the govt extends the due date; 2. File without the audit to show good faith; 3. tell the auditor to be ready to pay for the the DFVC fees.

Because of this confusion, Efast2 is also allowing people to submit the entire audit pdf for each attachment without having to split the individiual items out. Q24a: I only received one file from my IQPA containing both the signed Accountant’s Opinion and the supporting Financial Statements. Do I need to separate this file into the AO Attachment and the Financial Statements Attachment? The EFAST2 system checks that certain attachments required by the Form 5500 Instructions are included in a filing. Attachments must be included using the proper “tag” for the attachment. Ideally each required attachment should be its own file and attached to your electronic filing with the proper “tag.” If you do not include a required attachment or use an incorrect “tag,” you may get an error or warning message from the EFAST2 system that you did not include a required attachment. The EFAST2 Guide for Filers and Service Providers, Appendix E, provides a map of attachments with the “tag” used by EFAST2. The guide is available through the EFAST2 website at www.efast.dol.gov/fip/pubs/EFAST2_Guide_Filers_Service_Providers.pdf. If your IQPA report contains both the signed Accountant’s Opinion and the supporting audit report and financial statements, you do not need to separate the document. You may upload the entire IQPA report into the “AO” Attachment “tag” as a single PDF file. Also, if your Return/Report requires the submission of a Schedule of Assets or a Schedule of Reportable Transactions, you must upload these documents separately into the appropriate attachment “tag.” If you must file both schedules but do not have separate files, you may wish to either: Upload the same combined file into each of the required attachment type tags. You need to be careful doing this though because if your completed Form 5500 is very large (contains upwards of 100 pages of attachments in total), you will likely have difficulty transmitting the filing to EFAST2 due to the total size of the file. Create a separate document with a brief statement that the required Schedule of Assets and/or Schedule of Reportable Transactions is included in the Accountant's audit report attachment, and upload that document where you would otherwise upload the Schedule of Assets and/or Schedule of Reportable Transactions, using the appropriate tag(s) for those attachment(s).

Here's what Janice Wegesin says: Audit Not Ready: Should You File? I get this question a lot. If you were my client, I’d recommend you file by October 15 (or whatever extended due date applies), including an attachment that explains that the audit is not yet ready and that an amended filing will be submitted as soon as the audit can be attached. Also see information included in the DOL’s own FAQs regarding EFAST2 Electronic Filing System. The FAQs are posted at www.efast.dol.gov. Q25: Will the EFAST2 system still receive my filing if I do not attach the IQPA report with my Form 5500 annual return/report when it is required? The EFAST2 system will receive your filing, but submitting the annual return/report without the required IQPA report is an incomplete filing, and the incomplete filing may be subject to further review, correspondence, rejection, and assessment of civil penalties. Also, if you do not submit the required IQPA report, you must still correctly answer the IQPA questions on Schedule H, line 3. This means you must leave lines 3a and 3b blank because the IQPA report is not attached and must also leave line 3d blank because the reason the IQPA reports is not attached (i.e., was not completed on time) is not a reason listed in any of the available check boxes. You should still complete line 3c if you can identify the plan’s IQPA. Please note that failing to include the required IQPA report and leaving parts of line 3 blank, however, will result in the system status indicating that there is an error with your filing because, as noted above, submitting your annual return/report without a required IQPA report is an incomplete filing, and the incomplete filing may be subject to further review, correspondence, rejection, and assessment of civil penalties. Thus, if you find it necessary to file a Form 5500 without the required IQPA report, you must correct that error as soon as possible.

We've had two DOL audits this year on clients and both of the investigators asked to specifically see the statements with the required language.

No that's not what they are saying. Use the same 401(k) that is in existence. You won't create a new 401(k) plan. Just amend (if necessary) the existing plan, get new service providers and create the db plan. If the new service providers the sponsor is choosing didn't suggest this, then they are idiots and should not be used.

Andy, I haven't done a true DB, but we've done several cash balance plans. We haven't had any trouble with the XML so I can't help you with that part. As to the other, make sure you also have filing author credential otherwise you wouldn't have the ability to do anything other than sign. The "add attachments" button should be above and to the left on the screen when you go in to review. It might not appear if the credential isn't accurate. Hope that helps some.

Yep.

Hardships are still subject to the 10% penalty (with a few exceptions), so even if you could treat it that way, it wouldn't likely make a difference.