Bri

Should be, especially if these weren't brand new HCEs (like the owner's kid, since no pay in the lookback year) getting an accelerated benefit like that.

The second company certainly could become a participating employer to the plan. There'll be arguments for/against separate plans, but it's "easy enough" to do.

The hassle, of course, will arise when either LTPT (long time, part time) employee becomes eligible for deferrals only, and you have to set up the account for him/her.

They owe it to you one way or another, although most sponsors will throw it as plan benefits where possible to avoid running payroll taxes on it. If it's not going to be a match as you're not signing up to do 401(k) from your paychecks, for you they potentially could make it your "profit sharing contributions" for the year. Again, it avoids the related social security/medicare taxes, but you'd get your prevailing wage obligation through the plan that way.

There is, although I don't have a copy myself. It basically parrots the language in question 33a of the EFAST FAQs. Someone here should have a Word version or something readily shareable.

It's listed as 2024 Applicable, 2025 Applicable, etc., with a separate table for each year.

yeah, go to Data Entry -> Tables -> Actuarial -> Annuities Enter your interest rate, your mortality table, and the age range you want and it'll give you a list, looks like this:

Can your recordkeeping software export it? I have a 25-year-old Excel spreadsheet I use for DC cross-testing, and I know I was able to just manually enter the APRs for 8.5%/UP84 (which would almost always prevail for my plans anyway) for all relevant ages off a printout from either Quantech or Pentabs at the time.

If the loans were distributed as a benefit offset, then there's nothing to repay. The plan would have discharged the loans. If they were "only" deemed distributions, then the notes still "exist" and the sponsors could get some tax basis by repaying them with all the accrued interest.

The gateway is a nondiscrimination test on the nonelective contributions they're making, so I suspect you would use the compensation for the period the employee was eligible to receive nonelective contributions. In this case, since the SH entry date is earlier and it's made as a nonelective, that earlier entry date is the relevant starting date for the compensation determination. If they used a SHM then I'd suggest the opposite.

I'd be worried that a true-down is actually a cutback if the calculation and allocation are paired together at the pay period (rather than annual) level.

Of course not, but does the plan document address separate one-off paychecks separately with regard to deferral elections?

Is that an ASC document? I think they have separate QNEC options available, depending on how you filled out that 6D. Something where the BPD allows much more limited QNEC options unless you choose that "special contributions" option in 6D. Coordinate 6-D1's italicized notes with the BPD.

Sounds as though you need a new locator to find the old locator service!

I suppose unless there's a mandatory payout limit in the plan, there's no reason they can't stay await direction from the participant/beneficiary.