pmacduff

We used FDP back in the day. It was morphed over to Relius (actually Quantech first but that's another story). Anyway - I'm not sure I am chuckling, it's more scary I think. Why on earth is someone running a val on FDP and the DOS version no less? Not to mention the myriad of changes that have happened in the Regs since then.....

FWIW - I had this same siutation a few years ago and upon research found that if the roth distribution was qualified (i.e. after age 59 1/2 and first roth contribution was 5 or more years prior) then the participant could, in fact, take just roth out. Therefore I believe that the recordkeeper is incorrect....

ok -manufacturing client added COVID withdrawals to their 401k Plan but only up to $3,500 of the participant's vested balance. Employees have been back to work full time for months. (Furloughs were very brief for this particular client.) Can the Employer put an "end date" on these withdrawals so long as participants are properly notified? They are seeing a dramatic increase in requests "all of a sudden" and surmise that word is getting around from those who took distributions early on and fear now it's just being used to get funds out. I'm thinking the answer is "no" and that they must keep this in place until 12/31/20.....

Thanks RBG - semantics????

Small plan (less than 100 participants) client filed the 2018 5500-SF this year when filing the 2019 5500-SF when it was discovered that 2018 had not been filed. All previous filings since plan inception (1992) have been timely. Client received a letter from the IRS with regard to the 2018 late filing and a penalty assessment of $87,000! The IRS letter references the new penalty amount of $250 per day "effective for forms required to be filed after December 31, 2019". The size of the assessed penalty aside (!) any idea why they would use the new penalty amount for the 2018 filing? As referenced in other posts, the client has filed under DFVC with the DOL and paid the $750. Copies of same will be forwarded to the IRS and hopefully penalty will be abated. Needelss to say $87,000 would be a great financial hardship for this small client.

At least people don't say "Oh - you're in insurance?" like they used to back in the day when I started in retirement plans and said I worked for a TPA ?!

who knew? how long have they had that service? Don't remember being told of that. I go WAY back to the "FDP" days when you could call and actually talk to a real person right away. I figured those days were long gone.

I posted an incident but haven't heard back yet; sigh. sometimes it's just easier to ask those who actually work with the software because I can get a faster answer Patience is not one of my strong points ?

ok Relius gurus...I'm bringing this thread back up that no one answered back in January... Anyone know which financial interface vendor I can use to try and do the AXA import? The AXA website is similar to AF Recordkeeper direct, but we have issue with the AF imports and wind up using The Hartford link, which does work on the AF Recordkeeper Plans. I tried using "The Hartford" interface link on my AXA Plan and that doesn't work....SIGH Anyone?!?!?!

The Plan could use code 2, which eliminates the 10% premature penalty however if not 100% sure of disability status then the Plan should use code 1. If truly disabled, the participant then addresses that on his/her personal tax return with form 5329. My husband is totally disabled and one of his IRA withdrawals last year was coded with a "1" in error. Rather than go through the hassle of having the 1099-R reissued, I simply filed the 5329 form with our personal return and we did not have to pay the 10% excise tax.

After sitting in on quite a number of webinars including with the ERISApedia folks, I believe I have it correct with regard to the COVID loan repay suspensions but one can never be sure. Participant works for a dental office. The majority of the office is closed but said participant is, at least at this time, being paid full pay. Participant's spouse had hours reduced and now his Company has completely shut down and let everyone go. Participant would like to defer loan repays because husband is now not working at all. Is it correct to say that this participant would NOT be a qualified participant under the COVID rules in order to defer her loan repays?

This seems to be coming up more and more in my world, more with regard to the Federal withholding. Is it true to say that the former Employer Plan, if it does NOT offer COVID distributions, would treat this like any other terminated participant distribution (i.e. 20% Federal withholding if not rolled over)? Then the participant will handle the taxation part on their end when they file their personal return for 2020? - Or - is the former Employer supposed to process this as a COVID based on the former participant's presentation that it is a COVID distribution even though there is no intention to add the COVID provisions to the "old" Plan? Some of our clients are getting pushback from former participants that no taxes need be withheld as a COVID distribution (they claim to be furloughed now due to COVID at their current employer). Our client's plan did not adopt for COVID withdrawals because they are an essential Employer and not currently needing to add the provisions.

I was in a webinar yesterday with Derrin Watson and Stephen Forbes - during the Q&A this came up. It was recommended to use a Code "1" if the taxpayer is under 59 1/2 and then the taxpayer would address this when the individual's taxes are filed. I believe there was a form mentioned that allows the taxpayer, when filing, r to advise the IRS that there was an exception. That being said, I agree that when the time arrives next January, there will be a "special" code that will be used however in this case Susan was needing a code right away. My two cents...

FWIW - our State actually has a method online whereby you could submit for a determination/designation of whether or not your particular business was essential (on the State website). Another local TPA did submit a request for determination, which they shared with us. In the response (which came rather quickly I might add) they were advised that they were considered essential based on the information provided in the application. There were some caveats that" only those employees necessary to perform the essential functions should be permitted to be present and provided they follow all other guidelines of the Executive Order".

An ongoing 401k Plan is changing investment vendors and the question has arisen of whether or not they can add auto enroll EACA provisions at this time. I think the EACA provisions must be first day of the plan year start only (ie. as of January 1st for this plan) and cannot be implemented other times within the plan year. I've been asked by the advisor if the EACA provisions can be added due to the SECURE Act changes that allow a plan to be set up virtually any time now. I am correct in that would be if it was a brand new plan, if the client is adding EACA to an existing plan it still needs to be effective with a Jan 1st date? Thanks in advance.

I found this in the old archives and thought it might be helpful. "Posting eligibility results in a SubPerformBulkWriteNet Database write error when the employee type date and the date of hire differ"

Participant has an outstanding loan from roth source. Roth contributions have been in the plan for more than 5 years. However Participant is not yet 59 1/2 (will be in Sept 2020) for a "qualified" roth distribution. Plan is terminating. Participant elects not to pay back outstanding loan balance. How is that reported on the 1099-R form? The plan is an "old" balance forward plan. Pooled funds that will be liqudated to cash and all participants paid out this year. Thank you in advance for any and all comments! Should have carefully read 1099-R instructions first...this gets reported/coded like any other roth distribution since the loan will offset, just as a pre-tax loan offset would be reported/coded as a distribution in this instance.

anybody out there have any AXA plans that they import? AXA uses the same platform as AF Recordkeeper, so I was hoping to import the *.dat file but am having issues where Relius isn't reading the import file. Thanks in advance!

I did not carefully read the instructions for Block 8: "Block 8 - Only check the box next to the form types for which you are requesting an additional TCC. A separate TCC will be assigned for each box checked in Block 8." Thank you Kristina....

Thank you. Interestingly enough - I went back and found the original 4419 from 2011. It appears that if I had checked the 1099 box in addition to the 8955-SSA box at that time, then I would be able to use the same TCC number. Ulitmately I did not and therefore will have to file 4419 again for another TCC for the 1099-R forms . FWIW - I believe that if you are applying for a TCC for the first time you can check as many boxes as you want in Block 7 and would be issued one TCC for as many types of filings as you marked).

I have a TCC for the IRS FIRE site and file the 8955-SSAs for our clients after they review them. Can I use the same TCC to file the 1099-R forms for the few that we do? I wasn't sure if that same TCC code will work or if I have to prepare a 4419 and get a different TCC to file the 1099-R forms. Still have some small balance forward plans and have been preparing paper forms. Thanks in advance and hope everyone has a Happy New Year!

Thank you C.B. - it is a calendar year plan - I should have worded more carefully! I've edited the OP

Plan has individual accounts with a large recordkeeper (401k and safe harbor) and a pooled, Trustee directed employer profit share investment. TPA prepares 1099-R forms for the client for any distribution from the pooled Trustee directed PS accounts. In majority of termination (or retirement) payouts the participant takes the 401k piece at the time of termination and the profit share piece is paid out after the end of the plan year following termination; both per the plan provisions. However in rare cases the participant may be taking the PS portion first. Question is - in these cases should the 1099-R form from the pooled accts NOT have the "total distribution" boxed checked? Does it matter? Perhaps am overthinking this but it seems to be that if the 401(k) portion remains in the Plan, even briefly, it is not a total distribution until those funds are paid. Not a fan of these types of plans! UPDATE: For anyone else wondering - here are the form instructions: "Box 2b. Total Distribution Enter an “X” in this box only if the payment shown in box 1 is a total distribution. A total distribution is one or more distributions within 1 tax year in which the entire balance of the account is distributed. If periodic or installment payments are made, mark this box in the year the final payment is made." So as long as they both occur in the same tax year I can mark the total box.

I'm sure this is obvious but want to ask anyway: Client has discovered deferral contributions that were made late in 2018 and 2018 5500-SF has already been filed. Can I assume that they should now file an amended 2018 return indicating the late contributions?

Client has weekly payroll for staff and monthly for execs. Contributions are direct feed from payroll company, however the client still has to submit by pushing some type of button with the investment vendor to finalize the contribution. In any event, turns out that was happening only monthly in 2018 and 2019 instead of the staff processing weekly. All contributions are in and lost earnings will be calculated and deposited soon. The amounts are not large but affect ~approx. 3 payrolls out of each month. Client is under 100 participants. I assume the client should do the DOL VFCP first and then is it necessary to file the IRS VCP or is SCP ok?