Mike Preston

In the case of individually directed accounts, it is customary when someone empties their vested dollars that the remaining amounts (the non-vested portion) is immediately either: 1) transferred to a "forfeiture" account which is invested in short term interest bearing funds; or, 2) the investments in the participant's account are moved into the same kind. In any event, if the participant's funds need to be restored the amount restored is rarely diminished by a poor investment return. Balance forward plans handle this issue with much more grace.

What's that tag line I've seen floating around? 3 out of 2 people are bad at math.....

Yeah, this could be a question on a test: Describe the circumstances consistent with the above discussion that might cause an -11g3 amendment to be needed... [I can think of one].

Much more complete response than mine. But, while we are at it..... you are free to re-perform the a4 test for 2018 to satisfy the test. You aren't locked in by what the prior TPA did or assumed. So, accrued-to-date, restructuring, otherwise excludables... go to town!

There is a big difference between what the OP is talking about (a regular PS contribution) and what Larry is talking about. You don't need or want an 11g3 amendment to allocate a regular PS contribution.

CPA friend? He/She better hope you find a solution, because otherwise, friend or no, you need to tell the client that your CPA friend committed malpractice. So, let's get all the facts before we launch... is it an ez or an sf?

I'm aware of the counter-argument, but many volume submitter documents allow a restriction of 6 months where hours exceed 83 in each month. So one can get close to excluding those who might otherwise be excluded in a 12 month/1000 hour eligibility.

Yes, VCP. No other way.

It is not, so you can't.

Correct for 1 person plan. The $6,800 can go up to $8,200 if there are other participants in the PS who are getting less than 25% because the 25% limit is a plan wide limit and doesn't apply at the participant level.

Congrats!

Not on anybody's radar, as far as I can tell. The only audit relief being contemplated is the delay associated with 5500 due dates, if any.

Not me.

Also, your 6% is referred to as the nominal rate. My 6.16778% is the effective rate.

As has been stated at some point above, I think, 05-92 is incredibly unenlightening because the end of the suspension period coincides with the end of the delay period. It provides no guidance when the end of the delay period encroaches on a period of time when payments are not suspended. That is, when the delay period (1 year) is greater than the suspension period (8 months). As an aside, your 6% is 12 times the monthly rate (.5%) [typical banker's approach]. I would call that a loan at 6.16778% per annum. All of your calculations revolve around that interest rate, but I'm still having a hard time matching some of your numbers. For example, you use 9422.37 as of 5/31, but that is actually the amount outstanding immediately after the 4th payment is made [4/30].

RP95-51.pdf

And if the entire plan (all sources) are record kept such that a contribution can't be forwarded to the recordkeeper\trustee without attribution to specific employee? [Not that you need another reason to prefer balance forward profit sharing plans!]

I think she is 56, not 65.

How old is she?

Yes, in retrospect I think it should end up being 2 different payment amounts (ignoring the suspension period where there is a zero payment). I'm just not willing to invest time in a spreadsheet where there are this many unknowns.

Anything is possible without guidance to the contrary!

I think I concur, but the specifics still bog me down. Going back to the detail of the loan that Luke and I have discussed (monthly payments at the end of each month), are you arguing for the following: Original payment amount per month: $200. Payments on and after 4/30/2020 through 12/31/2020 are delayed for one year. Payments from 1/31/2021 through 3/31/2021: $200 per month Payments from 4/30/2021 through 12/31/2021: $200 * (1 + i) where i is the loan interest rate. If i = 4%, each of those 9 payments is $208. Payments from 1/31/2022 through a date which is 9 months after the original loan due date which reamortize the loan on a level basis through the date which is 9 months after the original loan due date That is, the reamortization period ends on the date which is X months after the original loan due date; where X is the number of months where payments are not made AT ALL. Alternative 1: The reamortization period ends on the date which is 12 months after the original loan due date. Note that in this case the monthly payments during the reamortization period are likely to be less than the original payment of $200. In either case you are arguing for 4 different monthly payment amounts: 1) The initial amortization amount 2) $0 for the period that ends 12/31/2020 3) [1] * 1 + i for the balance of the payments before the end of the 12 month period 4) Reamortization amount Anybody care to tweak this?

Sorry, but don't. Just don't. I don't have time to go through all that you have written which is less than perfect.

The latter. The former leads to 52 reamortizations in the case of weekly payments. Austin's pdf which displayed a weekly amortization schedule only had 1 reamortization, didn't it?

You miss my drift. I was congratulating you on throwing out an example which lends itself to a detail analysis that holds water. It certainly brings the issue I was concerned with into focus. I'm working on a spreadsheet that calculates the re-amortization amount but as you might expect it gets complicated. I'm allowing for three separate interest rates: original loan interest rate, interest rate to use during the deferral period, and re-amortization interest rate. Yes, they can all be the same rate; they just don't have to be. And for the re-amortization to have a repayment frequency different than the original loan (but both are restricted to weekly, bi-weekly, semi-monthly, monthly and quarterly. May be a few weeks before I'm ready to publish.