Mike Preston

Nothing prevents it! But doing so eliminates one of the reasons that CB-or-die diehards use to justify their stance: the client likes the account balances to equal the assets.

But not until after the new year because the IRS has the site down for maintenance until 1/2/2019. It was supposed to go down about 40 minutes ago. Haven't checked that it actually did. But one is not needed to set up a plan.

Even if you could create an ERA as a complete replacement for an NRA, wouldn't the MVAR calculations have to consider the ERA?

They have never been made generally available in the past. You'd have to check with ASPPA.

I think I disagree if I understand what you are saying. In fact, it is exactly the opposite. You and I are each 3 years into a plan. You have funded to the hypothetical account balances. I have funded to the 404 limit (generally 33% higher than what you have funded). Another 2008 comes along and everybody's investments suffer a 33% decline. You have to fund a &*%$-load to fund to the hypothetical account balance. My plan's use of the cushion in the past leaves me adequately funded. Since, by definition, the benefits you define have to be greater than those I use, given the same contributions for the first three years, interest rate volatility is much higher in your design than mine. I have found that there are sometimes good reasons for small plans to adopt a cash balance plan. Keeping track of who is supposed to get what from a plan when there are multiple owners, for example. But for the one man plan? Rarely is a cash balance plan the best fit. Come to Mary Ann Rocco & my session at the LA Conference next month for more discussion of this stuff.

Yes, No, Yes.

It isn't very grey. Maybe the teensiest of shading.

I hope not.

The Easter Bunny, Santa Claus and a Roth Profit Sharing plan all walk into a bar....

Only if you want to have your plan remain qualified. IOW, yes.

You are correct.

The owner is a hog, as in pigs get fat and hogs get slaughtered.

Once you hear, please share!

Huh?

I think Calavera and SoCalActuary did a good job of answering. The only nuance I would add is that the 415 limit at some ages depends on the plan's actuarial equivalence assumptions. If they have an impact on the 415 limit then selecting the actuarial assumptions which maximize the lump sum can be done at plan termination via a plan amendment (which would of course effect everybody in the plan). Remember that the 2007 415 regulations require that the 415 limit takes into account age in completed months. Lots of moving parts.

Here is my concern regarding the implementation of part or all of these new rules: once a change would force a modification to the Safe Harbor notice the requirement to re-issue the Safe Harbor notice and delay the change for 30 days kicks in. I think. Anybody agree?

Not eligible for EZ. Normally, would file SF. But remember, if plan has non-qualifying assets and would otherwise file SF, have to file long form 5500.

PC? Partnership?

One doesn't trump ambiguity. One resolves ambiguity.

I wonder if Form 4506 would work?

So much for easy peasy! It looks to me like the loan went into default around the end of 2017. It is very close between 12/31/2017 and 3/31/2018 so the particulars matter: actual interest rate applicable, plan provisions (or loan policy) regarding timing of default, how much is due on late payentsm etc. So, you need to check your loan policy and plan provisions to figure out the details, but with it going into default you can only correct through EPCRS (somebody check me on this). And, yes, reamortization of the amount outstanding over a period that doesn't extend beyond 5 years from August 2017 (the loan origination date) should be easily approved.

I would have to see what the loan amounts were, terms of the loan, etc. before being sure, but I would expect that unless the loan payments were ridiculously low as long as something was paid each payroll that the loan is not in default. A simple spreadsheet should be able to prove it. So what if the participant is a bit behind in the amount due? Calculate the amount that the participant should deposit to bring the loan up to date, have that deposited and change future payments to the correct amount. Easy, peasy.

I know a guy who knows a guy who says that they had this exact scenario. He also instructed those involved to not allow continuing deferrals after the acquisition date in the seller's plan. They had to wait until the purchaser got their payroll act together and they entered the purchaser's 401(k). There was a period of about two months between the acquisition date and the entry date in the purchaser's plan (special amendment to establish a special entry date for these folks). To do otherwise would subject the seller's plan to a claim of violating the exclusive benefit rules.

I doubt it answers his question because the question is so weakly formed. What in heavens name is a component in this context? It can be too many things. Floor/offset? DB/DC general tested plan? Rollovers? You hit the last one but there are even more.