RatherBeGolfing

It never hurts to develop a relationship with your members of congress. They work for YOU, and if they have a good staff they will also want to develop that relationship. You can also volunteer for Government Affairs Committees for the various industry organizations you may belong to. I know a lot of people here on the boards are already involved, but they are almost always looking for new members. Participating in industry PACs is also helpful.

I have no problem with change, increasing coverage, and so on. The problem is that we are making huge changes on an almost year by year basis at this point. Major changes like LTPT or lowering the statutory age maximum from 21 to 18 cant drop year after with a very limited time until its effective. We need time for major changes or chaos is all but guaranteed.

SECURE 3.0. I do like the Roth IRA to Roth 401k rollover possibility though...

I for one look forward to seeing the exhibits Austin will use in front of Congress... Can you say Groovy Baby! And Brians direct dial is 867-5309... Ill see myself out now.

I wish... I have high hopes for SECURE 3.0 though!

Just don't file it late if you were not required to file. I have dealt with far too many late EZs over the years. The IRS does not care that you were not required to file, if you file late you will have to pay the penalty or correction program user fee.

Some. Others were "I was just at the Dr. Acula conference and in one session...", or "Forbes/WSJ just had this article..."

"Dad, I don't care that the IRS dropped a new rule, can't I just eat my happy meal and build my lego's?!?!" happens way too often...

I think we can add Kelsey Mayo to that list as well. I have a very short list of trusted sources (Brad Pitt is on the list) on this topic. We should all be very careful with articles/blogs aimed at a wide audience, as they tend to skip some of the more technical issues that are too complicated for a wide audience. You could easily spend an entire article just discussing the "shift to plan year" issue, and many non-industry readers still wouldn't understand it.

The many articles floating around have created quite the issue. They had people convinced that the first LTPTs would enter on 1/1/24 when the first LTPTs could have entered as early as February 2023 (I suppose January 2023 could be possible but I haven't seen an example). Oversimplification and lack of guidance until late 2023 was a bad combination.

Aaaaaaaaaaand get ready for a tsunami of questions on match and non-elective contributions as Roth....

Happy holidays @Belgarath!

We need a "go directly to ERISA Attorney, do not pass go, do not collect $200" card for these situations...

This is really a possibility for any plan today. Look at the forfeiture usage lawsuits where plans are doing something that is permitted by most pre-approved plan docs.

While not universal, I do agree that many still have a "I want a local TPA" mindset. Or they simply go with whoever their CPA or advisor likes to use. Which brings up an interesting question @Peter Gulia If fees are paid with plan assets, when do you draw the line between the benefit received by having a local provider and the reasonableness of the fee?

Without getting into to specifics or actual fees, there are some huge differences in the TPA space. Its usually driven by what is acceptable in regionally. As an example I know firms in the northeast that charge anywhere from three to six times more for a pre-approved plan document than what I would consider average in the southeast. Not quite as much as what you describe, but still a huge difference for something like a vanilla 401k on a pre-approved document. Higher cost usually leads to higher fees, but 6X for professional services is a stretch in my opinion.

Thanks Austin! I'll let the Operations folks know so they can test it out. Much appreciated!

I agree with CB, I wouldn't recommend this until we have guidance. No telling when that will be.

Thanks for suggestion Paul I, I'll look into that.

We are coming across issues where the vested balance is more than the actual balance for certain rehires. Im waiting on the details, but in a nutshell: Participant terminates in 2021 at 20% vested and takes a partial distribution. Participant is rehired in 2022 and is 60% vested at 12/31/23. Relius says that the vested balance is more than the actual balance in the account. Any ideas?

I know a lot folks who aren't that keen on self certification in general. They may not feel comfortable with the self certification aspect or a possible "run on the bank" when employees know they just need to self certify. We saw similar issues with CARES distributions, some plans had just about every NHCE self certify and take money out.

Wait to make the decision to provide or omit until we have clear guidance on how to administer it?

In other words, having more liberal requirements for deferrals to get around LTPTE rules, thus they are NOT excluded solely because of LTPTE rules, so you don't get the benefit of excluding them from SH per the LTPTE rules You could probably find another way to define your excluded class.

I had a client get this as well, and the trigger seems to be that the second return is filed with the incorrect EIN. BTW, when I spoke to the IRS regarding this issue, they said the fix was to file NEW returns with the correct EIN (knowing that these are late and that the incorrect 5500 was filed timely). Since these will be late, you will get love letters from the IRS, and you will need to submit a request for abatement. It takes a minimum of 30 days from receipt for them to review the abatement, but in most cases it will take longer. During this time, penalties and interest will continue to accrue and the client will keep getting notices from the IRS. Has anyone completed this process successfully? Or did IRS tell you to correct a different way? Im just not loving setting yourself up for a penalty when abatement is not guaranteed, and you technically lose the opportunity for DFVCP if abatement is denied. I cant see a reasonable IRS agent trying to assess a $250,000 maximum penalty for an incorrect EIN, but...

Not that I'm aware of, but that is a concerning development... Large amounts?