doombuggy

Thanks for your thoughts, Tom. I think when the forms first came out, I was counting them, but now that the forms have been added to Datair's software, I think they do not get counted. At least that was my interpretation of the instructions... As I mentioned, we use Datair, so I will give one a try to see if I get a similar error.

A co-worker and I were talking about this last night. We were mostly talking about taking the ASPPA & EA tests, what was hard, how many times, etc. I took the ERPA test in the late summer of 2009 and Feb 2010. to be honest, I was surprised that I passed both, as I felt they were difficult. I do not work with DB plans, hence the reason I never took the DB portion of ASPPA's exams to earn a QPA. Part of me was" I don't work with DB plans" and part of me was "some of those ASPPA tests were hard!" When they changed the testing in 2004, I decided to retake the last test to earn my QKA in Dec 2003. After months of studing those D*** permited desparity questions, I finally passed that test. I had mixed feelings about ASPPA's decision to award the QPA (if you apply for it) when you pass & receive the ERPA. For someone like me to is one test (assuming it is still one, i don't pay much attention) away from the designation, well....but someone in our office who has NO designations, now has the QPA because he passed the ERPA. I didn't think that was right. Currently, we have 4 ERPAS in our small office and two of them have taken the ASPPA exams for QPA and CPC; I have the exams for QKA, and one who has no exams. I hope that if any of our clients look at the 4 of us for experience, they look at each differently, as we all have different experiences. If I was interviewing for another employement postion and the interviewer looked at my designations and felt it necessary to ask me about them, my asnwer on the QPA would be what I stated above.

If I have a person who I am reporting as a "D" they do not get counted in line 6? Those people that I am reporting as a "D" on the 2009 form terminated prior to 1/1/2008.

I have gotten this for aobut 4 clients. It says that the plan administrator's [and plan sponsor's in a seperate error code I-104SF] userid and pin are missing or invalid. The filing must contain this valid information. In 2 instances of mine, the client/trustee did not have the same email address that I used to send them the published link, etc in their filing credentials. In the other 2 instances they did, and we can't figure out why the transmission was stopped. Of course, not being there with the client actually does the e-signing to know whether they are doing it correctly can be a hinderance. But they must be doing something correctly, as they e-sing it and I receive notification that is it signed and ready to be transmitted. Anyone else have these frustrating problems? thoughts on this !@#$% issue?

Notices were given within the required period and the terminaiton date has passed. I just got the census info and an calculating the safe harbor for the short plan year. the plan sponsor will be paying the S/H. When I run the ADP test, it shows as passing since the plan is a S/H plan. If not for the S/H, it would fail. The have the 3% non-elective. they still get the automatic pass on the ADP since they are making the contribuiton, correct?

My boss did a contribution calculation for a sole prop uni-k, and now I am left to complete (ir print) the 2010 valuaiton. The plan's doc says comp is 415c3 with no exclusions (she did the document also). The comp that is reported in the system is $24,000.00. The deferrals reported are $22,000 (with an age reported as 50 for 2010). Boss calculated a profit sharing allocation of $4800. This leaves a total of $26,800 in total contributions for the year. This is more than the person's comp for the year. I think that is why I am getting the message. thoughts? We have Datair, so I am also going to post this on their message board to see if maybe it's a glitch and something that can be ignored. This is the first year for the plan, so no 5500 filing is needed, due to the amount. Thanks for your thoughts in advance!

Keep in mind that the "plan administrator" may be the plan sponsor (your former employer) and NOT the TPA (the recordkeeper of the plan). I second the advice of calling the DOL.

But when you read the instructions for 6a & b, only 6b mentions "and who are reported in Part III of this form." In the case where I have 1 participant to report who was previously reported on Form SSA and was paid out in 2009, so needs to be reported as a "D" in 2009. In this case, I put "0" for 6a and "1" for 6b.

Two of the ERPAs in our office went to the conference earlier this month, and in the session handouts, there was a revised list. I pass the 2nd exam in Feb last year and earned my designation in May. 8x2=16, so I needed 16 credits for 2010. Since my cycle is 3 years, the list now seems to tell me that I need 64 credits, not 72 (total). So I am doing well, since I went to Sungard's orlando conference in February, earning 19 credits. I am not sure if this list is posted somewhere on line....

No, you are not following me. I use Datair, we do NOT use IFILE. The instuctions/list that I mention in my post above was given to me by my boss, who had processed Hs thru EFAST2 before. since this plan has a fiscal year, this was our first EFAST2 submission. My boss had 2 attachments to each of the 2009 plans he had with sch h and neither one had an attachment called "accountant's opinion." Needless to say I had to post an amended return with the exact same stuff as the original; I followed Datair's instrcutions and copied the CPA's pdf into another PDF and called it "accountant's opinion." The DOL needs to do a better job with their guide book (which I proceeded to complain about to them in an email). I hope no one else has the problems I had with this.

I just got into a screaming match with one of the EFAST2 people. Their stupid website claims that in Appendix E of their EFAST2 Guide to Filers & Service Providers lists the Types of Other Attachments. Appendix E has something to do with PINs. The list from a year ago (doc version id 4.2/032310F) has a list, with 5 items on it for Sch H. "Accountant's Opinion" is not one of them. While I attached the opinion in "Financial Statements" as the CPA did not split out the PDF file, and sent a sesond seperate attachment called "schAssetsHeld" which was the last page of other attachment, I now have to resend the entire thing as amended, because it's looking for a third attachment I didn't know has to be seperated! I am so :angry:

I think my confusion was that I thought I was required to include 5 attachments, but I really only have 2 attachments (financialstatements & schassetsheld). while I did remove the schedule of assets from the original PDF, it is also left in there, as it is just one page. should be ok. My other concern was the name of the attachements. I named them in accordance to the EFAST2 guide.

It's a 15 page PDF file that they just sent me a finalized version of. It's called "Financial Statements & Supplemental Schedule with Independent Auditor's Report." I know the attachedments for DB plans are suppoed to have specific titles when sending them via EFAST2, and the only one I can find that pertains to Sch H is "FinancialStatements." Oh, on pg 3 of H, opinion is "disclaimer."

This client is a fiscal year plan that ended 8/31/2010, so this is their 1st EFAST2 filing. They are my only large plan, so I have not filed any 5500s with an attachment on EFAST2 as of yet. And yes, it is due on Wed 6/15....CPA just sent me the final Sch H and a draft of the financial stmt w/IQPA. They are waiting for the client to sign off on it. Note the draft they sent to me is not signed by the CPA (she usually signs her company name on the Independent Auditor's Report page). When this was sent in paper form, both the auditor's report page and the financial statements were bound up together. The draft copy that was sent over this am was the same - both pieces together is the same PDF file. Is this ok? What is the attachment supposed to be called - "FinancialStatements?" Thanks for your help! I need to publish this on Monday for the 2 trustees to sign so I can transmit it by Wednesday!

This client doesn't send us copies of their deferral election forms. I have sent out the report for their 2010 safe harbor match contributions, and we have addressed the deposit topic in the letter. I think their accountant has to step in and tell us what's going on with these deposits. I obtained a list of deposits made in 2011and they are looking a little more consistant for 2011...

Plan covers 100% owners and the employees of her small office. There were 4 people eligible for 2010 and only the owner and another employee/participant made deferrals. My concern is regarding the deposit of owner's deferrals. I have a W-2 for her, so should I assume that she is paid with some regularity? My real question is do the safe harbor deposit rules on deferral deposits apply to her? Regardless of whether she is paid with regularity or takes draws? My problem is that all of their deposits made to the pooled account for 2010 are listed as "EE Contributions" (plan has safe harbor match) and while there was a large deposit made in January 2010, it was not large enough to cover the deferral receivable from 2009. In fact, when I add up the deposits, it takes until May 2010 to cover that receivable. While I do not have a breakdown of the deposits, you can tell that the small deposits are for the employee, and the larger ones are for the owner, due to their annual deferral reported on the W-2. So would owner's deferrals be considered late? Thanks for your help in this argument.

We always do a notice, although I see that is doesn't seem to be required for non-pension plans. I am thinking that if a 401(k) plan has safe harbor, then it would need a notice RE: stopping the safe harbor. Agree?

I realized that you posted this awhile back, but my answr would be yes. At my prior employer, we had a plan that terminated due to a buy-out of the plan sponsor. One participant couldn't get his act together to get his distribution done. He had about $50k in the plan, and the new owner had to pay us for an annual val & 5500 for another couple of years after everyone else had been paid out. This was circa 2000-2002. Sounds like you are on the right track though.

Thanks for the link. This is the first one I have seen, and I have the administrator of a large fiscal yr law firm plan freaking out because this isn't ready and their 2009 filing has been extended to 6/15.

Client sent checks to investment carrier for the 1/31/11 pay period on 2/2/11, but they never made it to the carrier. Broker noticed this on 3/7/11 and checks were reissued an deposited on 3/11/11. The latest they should have been deposited was 2/9/11. I have calculated the lost earnings which total $78.45 (used the DOL calculator). I've never filled out a 5330, so I am thinking I need to complete the Sch C section of the form, but what dates and dollar amounts am I supposed to use? the date that the dpoesit should have been made by (2/9) or the date the deposit was actually made (3/11)? The amount of the deposit (each check, as there were 5 checks) or the amount of the lost earnings on each check? My boss has communicated to the client that the excise tax is 10% (I think it is 15%) on the lost earnings. Is that correct?

The trustee/plan sponsor of a 1 person PSP (which covers just him) called me today to see if he could use about 1/3 of plan assets to purchase land. He told me that eventually, he would like to sell the property to his wife, via a 3rd party, as they want to build a home on it. Apparently, he laready communicated his "desires" to the broker, who after conferring with my boss, told him that it was not a good idea, and to speak to an ERISa atty in his state. I guess he didn't like that answer (he really wants the property, but I am guessing he doesn't have $700k sitting around to buy it). I wanted to find some documentation in the EOB (ERISA Outline Book) that talks about arms-lenght transactions. his thought process is to buy the property with the plan assets, and in about a year or 2 (after they sell something eles, I think), he wants to sell it to an in-law who would turn around and sell it to the wife (who is not a part of the plan, just the trustee/plan sponsor/participant's spouse). I'm thinking this could be prohibited, but wanted to site him. Anyone know where in the EOB I can find this? We have the 2009 edition, but any hints or tips would be helpful...

Participant terminated last month and has submitted his paperwork for distribution. The plan is daily valued with Nationwide, and we release the distributions online. this guy has Roth deferrals and safe harbor non-elective. He is requesting that both be rolled into a Roth IRA. Tag has told me that this can be done, so I just went on Nationwide's site and processed the Roth portion of the distribution. Here are my questions: The distribution is automatically coming up with a code of BG. Is that because the Roth has only been in there since 2008? What code should the SHNEC portion of the distribution be? There are so many darn codes now...He'll need to pay some kind of taxes on that money at some point, probably sooner rather than later. Can you tell this is my first Roth distribution?

I found out yesterday that one of my clients authorized 2 distributions from the plan last year. The plan has individual accounts with Fidelity (who carried out his orders, no problem!). One participant was terminated in early December and received 2 checks last month. Since I have no financial statements (trustee working on that...), I assume that this check was issued with out federal withholding. EE rec'd a total of $849.19. The other distribution was issued to an employee/participant in September for the amount of $3000. This participant had a vested account balance of $4047.03 on 1/1/10. The plan allows for in-service w/d at 59 1/2 (she's 28, so that's out), hardships under the safe harbor standard, and loans, with no restriction on the reason. 1) former employee needs a 1099-R showing the dist; how about filling out a distribution form after the fact? 2) current ee is a bigger problem. From speaking to the trustee this monring, it does not sound like her problems qualify for a hardship ("she needed the money to pay her bills, and she had car problems...") - but that's an assumption on my part. Do you think we can set up part of this distribuiton as a loan (from her safe harbor source) and the remainder as a h/s from her deferrals? Fill out the necessary paperwork and set up the loan repayments going forward, but the loan should be no more than 5 years after the date she received the check? If she doesn't qualify for a hardship, could we do the loan thing to the max dollar amount she can take and the remainder would be a deemed distribution? If the entire distribution should be deemed, how does that effect the plan? The plan does have a bond in plan, for 10% of plan assets. So her 1099-R should be? What a mess!

So sorry to hear about this. Prayers and pixie dust sent Dave's way.

I just got a call/fax from a client who got one of these from 2008. They didn't have any distributions in 2008 - small client w/very low turnover. I told her to mark it "no distributions - not required" and send it back to them. Our tax dollars hard at work...