Bill Presson

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.

Cathy, the deferral limit is a calendar year limit, so the employee is allowed to continue her deferrals. Just make sure the employer's payroll has the limit set in their system on a calendar year basis.

Most, if not all, DB plans are in the process of being restated. $1,800 is pretty inexpensive compared to most DB restatement fees that I've seen.

I would recommend getting their answer in writing.

They are your credentials. So modify away.

We do not collect or review beneficiary designations. We have the employer review the forms and maintain the originals in the personnel files. We don't even keep copies and if anyone sends us copies, we shred them.

little glops If you put everything in the single pdf for accountants opinion, you'll get a validation error if you've indicated there are assets held, etc. and there's nothing in the little glop slot. Thank you. Is this an EFAST2 validation error or a Relius error message. If a Relius error message, can Relus still produce an xml file, which will be accepted by EFAST2? Your explanation was my suspicion. The auditors I deal with appear to be anti-glop and also anti-reading DOL instructions. My hardfast position is to maintain integrity of the process I will in no way, shape, or form alter the attachments they send me. Thus, when they have sent me there auditors report and say everyting is there, I go back to them and have asked for little glops. Owing to my pertinacity, they are finding it difficult to sit down after dealing with me. Actually, this is exciting since I feel as if I am returning years of tit-for-tat. More seriously, I believe if I do alter their attachments, then I am looking for trouble if DOL rejects. Well, God Bless You if you get the entire package broken up in the correct piles of glop. We're working to get the auditors in our acctg firm to understand the process, but that doesn't mean the auditors on the plans that we're the TPA for will understand. We're taking a bit more of a practical approach and just doing the necessary surgery on the GLOP pdf to make the little glopules. If the DOL comes after me for it, that's why we hire attorneys.

little glops If you put everything in the single pdf for accountants opinion, you'll get a validation error if you've indicated there are assets held, etc. and there's nothing in the little glop slot.

We've had a few people do this and we recommend they use someone that knows what they are doing. We've had some success with the local office of these guys: http://www.theentrustgroup.com/

If I was a participant that joined the plan sometime in the last 4 years, I don't think I would agree.

What we have clients do and what they do are not always the same thing. The error specifically says the Plan Administrator user id and PIN are missing.

TPAMan is correct and that is likely what happened.

Unless you are using the option for having the client sign a paper form and submitting it as a pdf, there is no need for you to have any credentials at all if you are using web client.

Which is worse? 1. Consistent season long mediocrity? Or 2. Fantastic season play, with a playoff swoon (ala my Sharks?)

He was still young (meaning any age below mine), but he had been retired previously. That's pretty cool.

Hey, I know the guy was an incredible innovator, but I don't think the mask allowed him to play quite that long!

I wasn't trying to call you out. I just meant that it was something I had dealt with a long time ago.

I addressed this issue a long time ago. I got a general information letter from Jim Holland, dated May 7, 1993 that specifically says "Because rollover money is neither a "contribution" nor a "forfeiture", no portion of the rollover money is taken into consideration when determining the amount of premiums that may be used to provide an incidental level of insurance coverage." The question I sent was specifically in relation to using "seasoned" money to purchase life insurance. It's not a Rev. Rul., but I'm pretty comfortable with it.

Interesting. My bad. Wish I had a better answer.

It is my understanding when using the EFAST2 that you have to use the 2009 forms even if it is for an older plan year. So I believe you will have to use the 2009 SB to certify the 2007 plan year.

They do appear to be making progress. Contact them again just to make sure the item wasn't overlooked.

Probably forever! 5558's haven't been returned for a few years now.

The Plan Administrator has to sign. Based on the info I've gotten from the DOL reps on panels, they don't care about a plan sponsor signature. If the guide says that, it's an error.