Mr Bagwell

Yes. I should have said you may have to ADP/ACP test. I have found that the ADP/ACP will most likely pass with a dual eligibility design because you most likely will have no HCEs. But it does happen. The common problem is immediate HCEs due to owners wifes and or children coming into the plan right away.

I will assume the plan allows for more than 1 loan. So normalcy is the new loan is a separate repayment schedule. So choice a. I bet you have!! LOL.

You may to ACP test based on plan design.

The first eligibility computation period for ER is 5/1/2020 to 4/30/2021. Said employee is not eligible for ER money. My assumption is said employee did not work > 1000 hours in 2 months. So for this employee, you start looking at calendar years to see if worked 1000 hours for ER eligibility. 2021 calendar year < 1000 and not even an employee.... but still not eligible for ER. 2022 > 1000 hours I like 1/1/2023 for start of ER eligibility. Hopefully, the plan does not do the one year hold out rule, or rule of parity.... I don't like those plans....

if the loan went full term the sources would get the appropriate principal and interest?

Year End Data Collection? I don't know.....

Looks like gov forms, yedc, and doc exchange will be down. Seems like you can still do testing and the important stuff this weekend.

FYI.... Relius reports give all the information too....

Austin, i agree Austin. 2.0 feels challenging, messy, crappy....

"However, a corrective allocation is not required to be adjusted for losses. Accordingly, corrective allocations must include gains and may be adjusted for losses." So someone has to make a decision on what to do. i would document my findings and process with no adjustment. Or I would use the VFCP calculator for earnings and be done. Chances are someone has another opinion

I think the plan document will have a section about employees moving from one class to another. No return of deferrals. The employee was eligible at the time. wow, what a messy situation..... IF......... I would say W-2 wages if needed a top-heavy and gateway as the K-1 earned income is for non-eligible class. Keep digging.... Hopefully some others will chime in.....

Mr Dragon, You are asking questions that take much experience and many books to explain. With that said, keep asking questions and digging into the website for answers. I'll drop some hints: matches don't offset the gateway. If you design a plan to be Safe Harbor compliant, (many rules come into play) you may or may not be doing ADP/ACP tests. Again, depends on the design. If you add a profit sharing to a Safe Harbor plan, Top Heavy will come into play. If you add a profit sharing with allocation conditions to a 3% Safe Harbor plan, the allocation conditions are worthless because you have to add the conditioned out employees in the gateway test. Otherwise, you won't pass gateway. Please don't be offended when I say "find an seasoned pension pro that you work with and pick their brain". You are asking good questions, but difficult questions at the same time.

I agree. I work for an employer that matches 100% of 6%, no match on catch-up, with an annual true-up. What does this mean? Really nothing. The employer thinks they are not matching on catch-ups, and therefore, saving them some money. This is true and misleading in concept. 20,500 divided by 305,000 is 6.72%. Adding catch-up in only increases the deferral %, still capping at 6%. Less compensation and more deferrals is only going to get you the cap of 6% match which Patricia alluded. Keep it Simple comes to mind. I've seen this confuse employees thinking they are getting the short end of the stick. While in reality, if they defer 6%, they will get 6%.

To be clear, I'm not saying "tell the employee to not have catch-ups". we are in agreement.

Wow! They actually listened? That's awesome!

Yes.... but it won't work. Tell the Provider to stop offering Catch-Up selection. You said it's a large plan... can you get any traction if the auditor "found" (with your help) participants that are not getting the correct amount of match? They put a nice little finding on the 5500-audit package. If no fix is done, seems like you have a not operating according to the plan Ideally, the payroll provider should know that employee A is not into catch-up and should be getting match. Even if have Catch-Up "selected"....

If the participant doesn't even get into catch-up amounts, tell the employee to change the deferrals to no catch-up. As MWeddell said, it creates confusion.

Wow. Staying on top of this one sounds like a challenge. Rock on!

This plan would probably have me finding a new place of employment...... Seems like a big complication, but maybe not as bad as I think. Just because I am curious, does the Profit Sharing piece have any allocation conditions? What type of Profit sharing allocation? Cross-tested, ProRata, Integrated?

Sounds whacky to me.

There is a thread or two in regards to this. If I recall correctly, there wasn't much an employer could do to recoup moneys from the retirement plan. The best advice was to work with the prosecuting attorney to work out a deal of repayment. Not sure if any law changes have been made to help these situations...

EPCRS has an example for the safe harbor match plan. 2021-30 example 8.

Said employee did not work in 2021?

Are you sure you are past the correction period? The new EPCRS extended the timeline.....

I've only used Relius and Relius ASP..... so I can't be objective. 10 years experience. And it can be challenging at times. Hang in there. And find a place you can enjoy the work. Good luck.