Cathy from Chicago

Two plans merging 6/30 due to company sale. How are 7 keys determined with combined plans. What takes precidence, compensation or attribution as far as eliminating a key person? Thanks.

7 a and 7c are the same number and are "net" of the $6000 forfeiture. The problem is in the details listed in questions 8...employee contributions are the salary deferrals and are actual number...had the employer made a match the employer contribution would be a 'net' number (deducting the match forfeiture) but since no match was made yet there were $6000 of forfeitures sent to employer to reduce this plan year's match, question 8i doesn't tie in with 7c minus 7a as 'over' $6000. could the $6000 be considered a liability in 7b? If so, everything would balance. It also balances if I put the $6000 as an 'other' expense in 8g but it's really not an expense. I appreciate your time - new experience for me. thanks.

Non-calendar year plan - Match forfeitures sent to Trustee who uses to reduce future Match contributions. This last plan year employer suspended Match but it is now once again active. Roughly $6000 of Match forfeitures were sent to Trustee during last plan year and are now available for current Plan Year use. How and/or where is the $6000 of forfeitures shown on the 5500SF so it balances? List as an "other" expense? Any suggestions? Thanks

Thanks much for your quick reply...appreciate it.

Plan is Top Heavy in 2011 due to a participant being a Key in 2010; this participant is not a Key in 2011 - can he defer in 2011 as a non-key or will be still be considered a Key in 2011? Thanks.

Thanks, Bill, for your quick response. Appreciate it. Cathy 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.

9/1/10 employee eligible to join 401(k) Plan Year 9/1 - 8/31 Defers $16,500 by 12/31/10 Can she continue her salary deferrals 1/1/11 for 2011 W-2 Tax Year or does Plan Year prevent additional deferrals until 9/1/11? Never been asked this before so I appreciate help from anyone who knows answer. Thank you.

No there is not

A plan is active and uses a group annuity as 401(k) investment vehicle. Years ago the plan had invidual annuities as the investment vehicle and no contributions have been made to those annuities in probably ten years. Due to surrender charges on them, the participants had option to transfer 10% annually to their group annuity account as such was not subject to the surrender charge. Question: in my opinion, the participant may not roll over his individual annuity to an IRA if he is actively employed as the individual annuity is part of the Plan assets - his broker, however, told him he can. Answer?

Plan paid out all but 3 participants in '08, the year the company decided to terminate the plan. 2 of the remiaing 3 were paid out in 2009 and the last on 1/5/10. Company closed and there are no remaining employees. A Summary Annual Report doesn't haven't to be prepared for either '09 or '10, correct? I could see preparing an SAR if the Company was alive and well and simply closed the plan but this is a complete close. Thanks.

I'm with you on this question - other than commissions paid by brokerage firms and manual calculations for R shares for American Funds (which include broker comp) and TPA quarterly revenue sharing payments, our group annuity providers will not give specific expense information - I honestly don't think any one has a clue how to answer 8f. I called EFAST2 for assistance - they didn't know but left a message for the accounting dept of DOL to call me - they never returned the call. Asked customer rep at John Hancock if contract admin charge shown on Employer's annual Balance Sheet was the number to use - he referred me to the IRS as said he wasn't sure so was referring all questions on 8f to the IRS. Asked Securian (MN Life) using one plan as an example - was told approx. $170 - seemed too low so asked another rep who gave me an expense breakdown for same plan - expense calculated using their formula for that specific plan was $17,000! I have not been putting in our TPA annual valuation fee unless it was paid out of the Plan. It'd be great if someone somewhere could and would provide a specific answer for completing 8f.

I see many have viewed my little query but I've gotten no replies - Does anyone know if any mutual fund companies are required to report fees/commissions, etc. to plan sponsors for the 5500SF reporting? Or - is question 8f just ignored if no report available? thanks..

Our plans mainly are also self-directed but each plan has a QDIA so I've been checking off both totally participant directed as well as the 2T box. So far we haven't had any filing rejected but have no clue on the DOL timeline quickness for rejection.

Called AFunds this morning to see where required information for question 8f is located since their annual plan expense report explicitly states info is not to be used for 5500 filings. Repeatedly was told there were no other reports, the annual summary could not be used and this was all detailed in the recordkeeper direct agreement client signs when starting the recordkeeper direct program. Question - anyone here get better and more proactive information that me from American Funds on how to answer 8f? Any advice given will definitely be appreciated. Thank you.

Plan uses group annuity (John Hancock) as funding vehicle - are the commissions paid to the broker included both on questions 8f & 10e? Secondly, Hancock's annual 5500 Sch A report which gives the commission total also shows a $43 contract admin fee deducted from the guaranteed interest account, yet the annual balance sheet on the administrators report shows $740 as the contract admin fee - is only the $740 considered towards total on 8f? This is my first attempt completing the filing using EFAST! thanks for any assistance you can give!