Bill Presson

Congratulations! I know it’s eventually going to happen to me but I’m fighting it right now. 😇
Hope you get to enjoy it for a long time!

ADP refunds are not particpant-driven transactions.  The decision is made by the plan administrator.  The custodian should rely on the representations of the plan administrator and/or trustee in cases like these.
Most of the record keepers I dealt with took direction from me (acting as 3(16) Plan Administrator).  But I don't see why they can't/won't take direction from the Plan Administrator.
Are these brokerage accounts?

Congrats @Belgarath!!!  You are coming back to discuss SECURE 3.0 with us just for fun though, right? 
Right?  
Bueller???
 
 

Congratulations on the retirement.  Enjoy the next stage of your life!

Dude, congratulations!!!
You have taken the time and thought to make more than 6,700 posts to these message boards, over more than 24 years.
What a helpful and loving contribution you have made to your peers, the employee benefits industry, and hence to plan participants and plan sponsors all over the country!
Unfortunately, your request for retirement is denied.
(The fine print is in the Terms of Service, the plan documents, or somewhere.)
 

I have made the (not all all difficult) decision to retire at the end of this year. I have agreed to work a couple of days a week during the early part of next year to help out my employer while they hire a replacement, but it's a limited engagement. I'll be lurking on these boards for a while yet.
I'd like to take this opportunity to thank Dave and Lois for providing this magnificent resource - it has been a tremendous asset! I'd also like to thank all of you folks, past and present, for the invaluable assistance you have given to me over the years. I've certainly taken more than I've given, and your time, generosity, and expertise is appreciated more than you can ever know. It's not just the technical expertise, but the sounding board for discussions, sometimes griping (misery loves company) and humor in the face of statutory and regulatory foolishness that makes this such a great community.
I wish you all the best in your future endeavors (I'm trying hard not to gloat) as you continue in this business, and I hope you all have a great Holiday season! Take care, and again, a heartfelt thanks!!!

Sadly, telling a potential plan sponsor about how the safe harbor works during a sales meeting has no bearing on what they remember over a year later when you provide the contribution amounts.

Cuse is correct. If your client needs proof, you can point them to IRC sec. 401(k)(12) which requires that the contribution be made to "each employee who is not a highly compensated employee and who is eligible to participate in the arrangement." Also see Example 4 in 1.401(k)-3(c)(7) of the regulations which is exactly on point that you can not impose a last day requirement on a safe harbor contribution.

Did no one explain this to the client during plan setup?

I disagree with this. If it's an asset purchase, the seller will continue on and can maintain their plan with no impact on the buyer's plan (old or new) whatsoever.

https://www.irs.gov/retirement-plans/simple-ira-plan-fix-it-guide-you-used-the-wrong-compensation-definition-to-calculate-deferrals-and-contribution-to-participants-simple-iras
 

Happy Thanksgiving to all my BenefitsLink cohorts!  We’re closed for the week (but I did help a few clients with some amendments—don’t tell on me), so this is a week to recharge. 
 
Hope everyone enjoys family, food, and football!

Happy Thanksgiving everyone!  I hope you all get to enjoy time with family, a good meal, and of course, some football!
I'm not working tomorrow, but we have a lot of people out on Friday so that is my day to catch up on stuff without too much interruption.

I hope you all have a great Thanksgiving, unsullied by productive thought. (We are having our meal on Saturday, as many family members can't make it tomorrow, so I'll be working tomorrow - great time to catch up on stuff with no phone/e-mails!)

No. If initial eligibility is satisfied for 3% SHNE and someone enters the plan they get the 3% SHNE for however long they were employed and in the plan, whether a day, a week or through year-end.

From the way the OP is worded, it sounds as if the client does not want to assume any responsibility for signing a plan document without fully understanding what they were signing, and they now want to declare this is totally the TPAs fault.  One thing that is almost always certain, when the IRS discovers a disconnect between the plan document and plan operations, the plan document governs and the plan sponsor is accountable for the content of the document.  The only instances where the IRS possibly may be possibly swayed on a hope and a prayer is if there is an overwhelming amount of documentation contemporaneous with the adoption of the plan and the original intent to have certain provisions that were not reflected in the document.  The IRS more likely be agreeable to accepting the retroactive application of plan provisions that are favorable to participants and are not discriminatory in operation.
Given the changes in question, there should be no issue with accelerating the vesting schedule, but be careful with the change in NRA for any participant who is withing three years of age 62 (since attaining NRA would trigger full vesting).
Be a little wary of this client who will blame you when something goes off the rails, and make sure you maintain documentation of source data and any operational issues when they arise.  This is particularly important in this environment when plans can be administered base on documented administrative procedures that have not yet been codified into the formal plan document.

If the documents governing the plan provide no more than is needed to meet § 401(a)(9):
“The account balance is increased by the amount of any contributions or forfeitures allocated to the account balance as of dates in the valuation calendar year after the valuation date. For this purpose, contributions that are allocated to the account balance as of dates in the valuation calendar year after the valuation date, but that are not actually made during the valuation calendar year, may be excluded.”
26 C.F.R. § 1.401(a)(9)-5(b)(2)(i) https://www.ecfr.gov/current/title-26/part-1/section-1.401(a)(9)-5#p-1.401(a)(9)-5(b)(2)(i).

I hope your seventh book will be the music notation and lyrics of your songs about the law of retirement plans.

Derrin, I’m so very grateful for everything you’ve done for the retirement community and, especially for me. 
 
Without you (and Doug Jolley), I can’t imagine having survived the early difficulties in what became my career. Starting my own business way before it was rational to do so, I leaned rather heavily on PIX just to keep my head above water. 
 
Thank you, though that is woefully inadequate. 

Well done!  I can echo, after 40+ years as an actuary, it was difficult to "let go", so I endorse your gradual approach.  Retirement is great!

Derrin, I’m so very grateful for everything you’ve done for the retirement community and, especially for me. 
 
Without you (and Doug Jolley), I can’t imagine having survived the early difficulties in what became my career. Starting my own business way before it was rational to do so, I leaned rather heavily on PIX just to keep my head above water. 
 
Thank you, though that is woefully inadequate. 

Derrin, I’m so very grateful for everything you’ve done for the retirement community and, especially for me. 
 
Without you (and Doug Jolley), I can’t imagine having survived the early difficulties in what became my career. Starting my own business way before it was rational to do so, I leaned rather heavily on PIX just to keep my head above water. 
 
Thank you, though that is woefully inadequate. 

@S Derrin Watson, you have been a trusted advisor, teacher, lecturer, and author for my entire career in the industry.  I can easily say that you, @Ilene Ferenczy, and Sal have shaped me into the practitioner I am today.  I wish you the best as you start this new chapter of your life!

😮noooo!!!
Well, for the rest of us.  Thanks for everything over the years, Derrin, and enjoy the wind-down!

Darrin you are the one and only person who has ever done singing continuing education classes that I have been in.  You bring up your name in this industry and the conversation  turns to the signing instructor. 
You also taught all of us a lot in those classes. 
Enjoy retirement.