pmacduff

This has been discussed but most of the threads were older so I'd like to see what others think now. Plan Sponsor name and EIN (as well as the Plan name) were changed effective 01/01/2021. When preparing the extension for the 2021 plan year, the FT Wm software is using the old name and EIN, even after I updated them on the website. Can I assume this is the correct way to file the extension and then when the client files the 5500-SF form and reports the Plan Sponsor name/EIN/Plan name change on that it will line up with the extension that was filed under the old name/EIN? It makes sense to me because the EBSA has no record of the new information until the 5500-SF is actually filed. Just paranoid I guess and want to be sure.....

I had to smile when I read Annie's last post....I have worked on Relius my entire career (32 years). We were on FDP to start - boy those were the days! You could go to Miami for training and were treated like kings and queens, great training, great people, great dinners, etc. You called and got a real person when you had a question. (heavy sigh) We then transitioned to Quantech. Always used the stand alone systems for both FDP and Quantech. Then finally currently on ASP. One advantage from way back is that they keep the software udpated, which I like as opposed to having to do our own updates on the stand alone systems. It took some getting used to ASP (still getting used to it 🙂). The software itself is MUCH slower at times. Tried to blame our internet connection, but that is screaming fast for everything else and even the log in to ASP, so I'm pretty sure it's just ASP. Haven't had a LOT of service issues but you are right about the slow down on those too. Thankfully I haven't had to put in any incidents because I'm not able to log in to the Portal. I got locked out and then couldn't get it to reset so I have to call to get a reset for that and haven't had time.

From the ever popular Google search: "Can you undo a Roth conversion in 2021? You can't reverse your decision Today, recharacterization of converted Roth funds is prohibited by the Tax Cuts and Jobs Act. In other words, there's no going back once the conversion is done."

I have a few older plans where the client termed the Money Purchase Plan and most participants rolled those funds into the 401k PSP. The MPP funds had J&S so we have always kept it separated as "related money purchase rollover". when the client moved investment platforms we kept the source naming the same and have two rollover sources, one for unrelated and the other for the related MPP rollover funds. never had any issues.

My understanding is the same as yours that the audit requirement is based upon the BOY count. I think that the 5500 instructions seem pretty clear about that. I don't see any mention affecting the BOY count rule in the event of plan termination. I vote with you Pammie57!

I'm with Bill. Any plan I've ever had over the years that went from small plan to large plan, the auditors required all of the information from that prior year even though they were auditing the current year.

I'd want to know - did this occur in two different plan years? If so, then the participant got credit for the taxes that were paid in to the IRS on his behalf. That amount (which would have been reflected on the 1099-R form) went toward his overall total tax debt. Even if the distribution occurred in the current plan year, the participant would still receive credit for those taxes paid into the IRS on his behalf so I would say that the participant would have provide 100% of the distribution amount back to the Plan.

fyi - so I did receive a response to my incident from support that says (and I quote): "As long as Microsoft supports Windows 10, IE11 will be supported. However, as the ASP team moves the Relius Administration platform to the new data center (which is underway and in testing), you will be notified on when you no longer have to use IE11. When that takes place, you will receive instructions on the new method of connection."

I did post an incident to FIS but in the meantime am wondering if anyone else has heard when they are going to update the log in for ASP to use something more updated than Internet Explorer? We are getting the messages now that Internet Explorer will no longer be supported after June, 2022. We are surprised that FIS had not already migrated ASP to another browser... Thanks in advance!

Hi Dave - I like the fact that I can get different views/takes on situations (including situations I may not have experienced yet) and, as others have mentioned, that you can be brought to clarity on issues where you may not have been seeing the big picture. Been doing pension administration for a long time and appreciate that interaction between posters, moderators, etc. Lighthearted moments help too every now and again although it has been hard without Mr. Poje !

If a participant opts out after auto enroll and deferrals are distributed under the permissible withdrawal rules, are those contributions included in the ADP test?

As I recall I did not do well the first time I tried this but will try again. However the spreadsheet is asking me for a password to unprotect before I can enter any answers? Help Nevermind, I need to concentrate, I did not previously see the area under the picture to enter the song number. Perhaps I should not try this after all!

agree with chc93....

ESOP Guy we actually had that come up in a large plan audit (the whole 12/31/last day thing). In our case, the plan had been consistant in current and prior years whereby they counted anyone employed on the last "working" day of the year when the office was open as being "employed" on the last day and gave them an allocation. The client had someone term on 12/30 (it wasn't the last working day that plan year) and they didn't get an allocation. The auditors had no problem with it. While I know it can be dependent on which auditor you get, I've always advised the client to be consistant and as you mention - follow the plan doc!

IMHO: 1) Participant receives a PS allocation because they worked on the last day 06/30 and 2) They are working (actively employed?) on the first day of the plan year (07/01) so I say they are included as ACTIVE in the 5500 parrticipant count.

A portion of that Code section states as follows: "the qualified salary reduction arrangement maintained by the employer would satisfy the requirements of this subsection after the transaction if the employer which maintained the arrangement before the transaction had remained a separate employer." Both the SIMPLE Plan and the 401(k) Plan "satisfy the requirements of the subsection after the transaction....." If the client with the SIMPLE plan has to continue as an independent entity in order to to use the transition rule, how is that possible in a merger or acquisition? Now I am more confused.

Thank you Bird. So I'm clear - Even though the 401(k) client is just changing the Plan Sponsor and name on the 401(k) Plan to the "new" entity, there can be no transition year and the SIMPLE Plan must stop immediately? P.S. Can you direct me to any cites that I can use to help explain this to the client?

I don't work at all with SIMPLE Plans - client with 401(k) (my client) and another client with SIMPLE Plan are merging in a stock sale. There will be a third, brand new Company [effective 01/01/2022] with a new EIN for all employees. The new Company wishes to continue the 401(k) plan with the new Company as Plan Sponsor and terminate the SIMPLE Plan, which would happen regardless because there will be well over 100 employees after the merger. I believe I understand the transition year, which in this instance will be the 2022 plan year. However if all employees are now on the same payroll in 2022 (under the "new" Company and EIN) is it still possible to have the SIMPLE participants making SIMPLE contributions and the 401(k) participants contributing to the 401(k) Plan for the 2022 transition year? Thanks in advance. edited to add: So is this a dumb question because of course they would all be on the same payroll for the transition year? Also - the SIMPLE participants are going to be excluded by amendment prior to the start of the 2022 plan year. (Coverage is ok regardless.)

Client with a participant requesting a hardship in a plan that is with one of the large national 401k vendors called the vendor with some questions. (We are the TPA on the plan.) Backup documentation came up during the conversation and the client was told by the vendor that "unless the TPA needs the backup documentation then it isn't necessary anymore to get such documentation on hardships from the participant." Is this true? Did I miss something?

ok - so along with the age change for the first rmd from 70 1/2 to 72, I see that there are new tables for the calculations. Just want to be sure I'm understanding; it appears that the new table must be used in 2022 and going forward. Therefore for 2021 I can use the "old" table? That's what my software used as well but looking for confirmation... Thx in advance

my 2 cents - agree with Lou S and wouldn't you have the same scenario if a plan switched from an accrued to a cash basis? I realize that would only be for the one year, but it sounds like that's what you have here as well.

That's what we do - tell them that the client can request a copy from us if they can't find their copy. Then we send it to the client and let them provide it to whomever....

my belief is that the intention of the form 8955-SSA was so that participants who had not taken distribution of their plan account (for whatever reason) are notified of said account when they reach retirement age and apply for their Social Security Benefit. I've read many of the letters these participants receive from the Social Security Adminirtration when they apply for SS and it is indicated that they "MAY" have a benefit in said Plan. That being said, I suppose the semantics of a participant having a "deferred vested benefit" could lend itself to mean that either they couldn't yet take the benefit when they left (if only payable at NRA) or that they actively deferred their benefit until a later date and not that it was available to them earlier and they just didn't take it. However in practice I was always taught and assumed as Jakyasar says that you report anyone entitled to a benefit that has not yet taken that benefit (within the form parameters).

what about cold hard cash 😁? Sorry SSRS - hopefully you don't mind the humor - I think we all need it - but seriously very nice post and sentiment about the help you received!

yeah - it's that simple - was anyone a participant as of the first day of the plan year (i.e. what is the plan entry date)? If they were then assuming they didn't terminate on that day they would also be an "active" participant.