TPApril

I have pushed back against this, asking them to focus on 'intent' fwiw of their deposits and that while a cpa may thrive on creative accounting, their tpa cannot defend this approach.

follow up to my last post - cpa has advised plan sponsor to adjust the prior year contribution and treat a portion of that as making up the loan payments on a timely basis. The outstanding contribution will be made up timely. Not happy about this though.

Professional firm of partners. One Partner, a key employee, never started loan payments and now that we are passed the correction period, he would like to be up front and correct the loan by repaying missed payments with interest, reamortizating and submitting under VCP so as not to default. Similar to above posts, and Form 14568-E (rev 6-2018) Section IIB, he cannot use this form to file. So is a VCP not possible in this case? Best or only solution is to default the loan?

true, but the dates were changed from the actual case to be a more generic question, in this case it does matter actually. I just found it interesting to contemplate the event happening around 12/31.

They are set up as part of payroll which happens on the 15th, 30th of the month, although pay/deposit is actually made the following week. So the amortization schedule shows a payment due 12/31 that would have been deposited 1/5. It was missed and no further payments made so just trying to clarify if default date is 3/31 (based on 12/31 in amortization schedule) or 6/30 (based on when deposits were routinely made).

Thanks Bill! Yes of course, 3/31 & 6/30, not sure what I was thinking but I actually do know that ;).

Say payroll date is 12/31. Paychecks are not typically issued until the following week, ie in the following month. Loan payments were stopped. Would the loan default day (at end of 2nd quarter following first missed payment) be 6/30 or 9/30?

Makes sense for this particular business actually, but question has more to do with how a prior TPA completed the 5500, reporting the lower amount of $500,000 rather than actual bond amount.

For sponsors who have bond coverage greater than statutory limit of $500,000, I'm curious if 5500's are generally prepared with the actual coverage amount or the higher amount? Does it matter? Not necessarily for audit purposes, but it does matter when the 5500 signer cares.

Excellent points as always, I should have included that using the payroll version of comp vs the plan doc definition of comp is more beneficial to all employees. There would be no additional contributions or corrrective withdrawals. If they go with plan doc def some money would have to be pulled from the match.

Plan set up beginning of last year with a certain definition of compensation. On payroll, a different definition of compensation was used. To what extent can plan be amended retroactively to match what has been done in practice (ie self-correction)?

One owner has 4 separate businesses, all somewhat related, working at the same location, but separate employees. single or multiple employer plan? I'm thinking Single.

Employee level question - Employee elected maximum allowed into employer's Health FSA plan. Employee is terminating and has 2 questions: Is employee required to submit FSA claims prior to last day of employment (ie mid month), or last day of coverage (ie last day of month), taking COBRA out of the picture Can employee then elect any FSA amount with new employer, regardless of how much was either put into the account of first employer or reimbursed/used at first employer?

One consideration for incorporating the Vision plan with less than 100 ee's into the wrap plan as a whole - by doing so, the Vision plan will not have an ERISA compliant SPD which it may not have otherwise. The trade off of adding into the 5500 may be worth it.

Austin - two comments: Interestingly enough, this particular late deposit of one day was reported to me by the client (ie I've trained them well to take their deposit timing seriously) The question at hand, and all of your comments point more directly to the elephant in the room - ie the current regulations are too impractical, arduous and costly and need beyond belief to be revamped. Which leads me to another question - I haven't reviewed the new epcrs guidelines but saw something about de minimis errors being increased from $100 to $200 or something like that. What with greater acceptance of the reality of de minimis errors, can this example be treated as de minimis and ignored?

Austin - I don't think it's micromanaging, I think it's part of being a full service consultant. It's generally pretty easy to download deposit dates, most clients have 24 or 26 payrolls, some 52. If you're filling out the 5500 correctly that's what we do. Sort of old school in that we don't make the client do everything for us that we do for them?

I'm just curious what large plan sponsors do when it comes time to provide an updated SPD, or the SPD for a new FSA provider. Since electronic distribution remains opt-in for welfare benefits, do most plans print them out?

So Bob, would you recommend to the client that it not be included on the 5500 then?

Due to set of unusual circumstances, small plan Plan Sponsor that always deposits 401(k) contributions on time, deposited the sum total of $150 for 3 participants one day late (ie 8 business days after withheld). Report on 5500?

I was just curious what other TPA's might do regards to maintaining data for former clients. When do you delete it? Do you provide terms of deletion in your service agreement? What about long standing clients whose agreements never referenced a deletion policy?

this is not a life changing question, more of a curiosity. So 5500 deadline falls on a weekend and so is actually due 8/2. Would that make filers (without an extension) have an SAR due date of 10/2 instead of 9/30?

Medical Insurance company offers Vision as an option through its benefits, which itself is provided by a separate Vision insurance company. Some groups will buy the Vision directly from the Vision company, others will bundle it with the medical insurance. For those that bundle it, premiums, commissions etc are included in the medical company's provided Schedule A ltrs. That's all fine. The medical insurance company itself prepares its 5500. They do not include a Schedule A for their own medical benefits for its employees. They include a Schedule A for the Vision that they purchase from the Vision insurance company. Now, they are switching internally how they purchase their own Vision - they are now including it in the bundled option for themselves. So, the question - would it still require a separate Schedule A letter? Vision company does not want to provide one because of the extra accounting etc. but medical insurance company can run the accounting for themselves.

Sometimes I gotta ask a question that seems obvious but who knows... Are there options for types of pay to consider as eligible pay for a one-person S-Corp other than W-2 pay? Looking at the Plan Doc is not an option as plan is being set up right now.

One owner has two entities, currently no employees. Can he have different plans for each one and contribute the maximum to each? One currently has a SEP the other is starting up a new 401k PS plan.

I can't say I follow this. Situation in question: Participant dies at 64. Spouse is beneficiary. Participant would have reached RMD age 72 this year. Is factor based on surviving spouse age this year?