ratherbereading

Hence my comment - I figured he wasn't excluded from the contribution to begin with.

Why would they not have to make it?

The non-key HCE would still need a TH contribution.

Your best bet is to contact an actual TPA to discuss as they all have some differences, however minor. Our TPA functions as item 2 in your example with one person assigned a block of plans (under 100). We use Relius but the investment houses we work with are responsible for recordkeeping.

Maybe they want to do what one of my plans is doing - have a no-show job. The owner has his wife and kids on the payroll/getting W2s/maxing out their deferrals/getting employer contributions/and none of them work there. Ever. The wife is a stay at home and the kids have their own jobs. Nice work if you can find it.

Participant (80 yo) took an RMD in 2022 and a total distribution in 2022. His 2022 profit sharing deposit went in in August 2023. Now rolling that amount out of the plan. No 2022 balance to calculate his 2023 RMD prior to the rollover. What's the procedure? TYIA!

You're talking about 2 different things, I believe. Yes, your 401k deduction, etc. will be withheld from your final paycheck, but the Plan's legal document dictates when you can actually take a distribution. In other words, if you want to take a distribution of your 401k account, it's not going to be processed on your last day of employement. As you show in your plan's legal document, your distribution cannot be processed prior to 30 days after your date of termination.

It's not "stupid guidance", it's their plan document. You should have been received SPDs (Summary Plan Descriptions) during your employment and this would have been noted in there. Even though it's crazy California, in this instance, they are correct in delaying your distribution.

I have several plans with AFPP and don't get a participant count from them; I get it out of Relius. You will need someone who is proficient with Excel so you can get the right data into Relius. From there you will be able to get a census with the correct information.

But if it's 1 year of service AND 1000 hours, would it not be no since she didn't initially complete a year of service?

Plan does not allow for Roth currently.

Regarding catchup contributions starting 1/1/2024 going to the Roth source for certain high earners, is that only for W2 employees? What about Schedule C/Schedule K owners? And how would that work for those people whose money is in pooled accounts and not separated by source, other than by a TPA in their system? TYIA.

Methinks it's time to move on and turn the page!

Retirement age for most people now is at least 66 1/2. You can't collect social security until 62, so curious as to what the benefit is to doing this?

Yes if you're doing it on an accrual basis.

Does the plan document say that part time and seasonal employees are excluded? I believe that IRS guidance will require these p/t EEs to be eligible to participate after working the required number of consecutive years with 500 hours. They can still be excluded from employer contributions if they don't work 1,000 hours in a year. That is my take on it.

It should have been used each year!! Not accumulated.

We cash out anyone with $200 or less. Our fees eat up 75% of the distribution anyways.

Pretty sure I know the answer to this one but just in case ... 401k/PS plan- owner gives his 2 kids (they do not work there ever - they have other full-time jobs) the max 401k and accompanying SHMatch every year. They are on the payroll so get W2s. They do not contribute any 401k monies where they actually work, but can they get a profit sharing contribution from both this plan and their actual plan? No need to comment on the legality of this - been down that road with them. TYIA!

Luke, no they are not an owner.

DC Plan - employee terminated last month. To prevent her from suing the company (no details on that) they will be giving her $8,000 severance pay that will show on her W2. I don't think they give her the guaranteed 3% safe harbor on that amount because it was not given for services rendered and she would not have gotten it had she stayed with the company. True or not? The document discusses post-severance pay (bonus, commission, etc.) but not this. TYIA.

I need some help with this. Participant turned 70 1/2 on 11/16/2019. DOT 12/31/2003. Deferred RMD to 4/1/2020. RMDs were suspended in 2020. Did not take one in 2021. Should the first one have been in 2021? Thanks in advance!

Plan year end is 09/30/2022. Funds at Nationwide. Are RMDs done based on 12/31/2021 balance or the 09/30/2021 balance? Thanks in advance!

That is correct!

Yes you do!