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If a participant terminates in December of 2020 but has small compensation and 401k paid in January of 2021, should they be included in all of the testing for 2021?

A participant rolled over his entire balance to an IRA in 2019 without taking his RMD prior to the rollover. He will be taking the RMD now as it was just discovered. Is the only course of action to remedy the missed RMD by filing through VCP?

We are the TPA and we calculate the match for the client on a per pay basis. Their pay period ending date was 5/22 but the pay date was 5/29. The next pay period ending date is 6/5 with a pay date of 6/12. A participant met match eligibility on 5/24 and they are immediate entry. The client is thinking the person should not get a match until the 6/12 pay date because the pay on 5/29 is for time worked prior to her entry date. Our system processes based on the pay date and as 5/29 is the first pay after her effective eligibility date, we are thinking the participant is ok to get match. Any thoughts on if we should use the pay period end date versus the actual pay date? Thanks!

We are helping a client who is managing a new facility with a separate 401k plan where it was discovered that they have not filed the Form 5500 for a couple of years. We are working on gathering the information to file the forms;however, we are missing some key pieces such as contributions during the years as well as year end balances. What is an option for filing the Forms while missing holes of data?

I have a participant who had 4 years of service before he terminated. He then had 4 1-year breaks in service before he was rehired. He had 1000 hours in the plan year he was rehired in. The plan is immediate entry for 401k & a 1-year of service requirement for profit sharing. Does the participant come in for profit sharing during the year he was rehired since the number of consecutive 1-Year Breaks in Service does not exceed the greater of five or the aggregate number (4) of pre-break Years of Service?

I have a plan which excludes bonus wages from the definition of compensation. When running ADP/ACP testing, do I have to test using the compensation as described above or can I use the full year compensation? The client did not withhold 401k or give match on the bonus amounts.

I processed a death benefit recently as a lump sum distribution to the beneficiary (son of participant) and the brokerage house did not withhold the 20% tax. The field stated that federal tax was not mandatory to be withheld. Is there a place I can find the rules specific to non-spouse beneficiaries?

This happened during the course of 6 payrolls (April, May & 1st pay of June). It was discovered by the employer and the deferral elections have been corrected so I believe there is no need for a QNEC. I will go ahead with the refund to the 0% participant. Thank you for the help.

A participant filled out an election form and elected 10% to be withheld while another participant filled out the EF electing 0% withholding. The employer switched the participants deductions so the 0% participant had 10% withheld. Is a refund necessary to the 0% participant or is there a different solution for this?