RatherBeGolfing

Optional true-up with a determination period that is more frequent than annual? Is this a C3 pre-approved document?

The document controls. If the match determination/allocation period is annual or year end, you use full year comp less any exclusions like pre entry etc. I agree that we need more info here, but it sure sounds like 401k and match were effective 1/1 but the employer didn't get their stuff together in time to withhold on the first payroll. If that's the case, the sponsor cannot use its own failure to follow the document to limit the comp used for match. I would also take it a step further than @Paul I. Even without autoenrollment, if 401k and match were effictive 1/1 and the sponsor did not provide an opportunity to defer until February, you have potential MDO and probably owe both match and QNEC for failing to give employees an opportunity to defer in January.

When did it start for you? I have used the same link since ASPPA took over the EOB and I used it once or twice last week with no issues. My link takes me to right to the EOB, I click on the ASPPA log in link, and after username and password it takes me back to the EOB..m

With my prior Employer, a small regional TPA shop, this type of client was 15-20% of our business. It was probably double that 10-15 years prior. They were all old/older clients that started as pooled plans, usually with older management resisting going to a platform (some resisting adding 401k and for sure no Roth). The only way to make this work is realistic pricing. Many small TPAs undercut themselves when the price tag for the client is high. So while the billable is high compared to your small plans, you probably make much less money based on the spent. I would not take on clients like this unless there were other considerations like a good referral source that you don't want shopping around.

Nope. Roth is either allowed or it isn't, you cant limit it to catch up.

but only until regulators focus on intent...

So 6/30/22 PYE and most recent TPA SOC covers 1/1/21-12/31/21? 1. TPA can get gap letter to cover 1/1/22-6/30/22 2. IQPA can make a note that it wasn't available yet 3. Question why the IQPA requires the TPAs SOC. Plenty of small TPAs don't have a SOC audit and work on large filers.

Our Ops department confirmed with Relius. Administration will not be down, only documents and RGF Systems

you are on fire today Sir!

Most people dont pay much attention to the release of next year's 5500 in the middle of testing season I guess? ASPPA/ARA did mention it in one of the daily/weekly news emails though.

Oh for sure. I think there is a bit of a trade off with the audits themselves becoming more detailed (and more expensive), but probably not enough replace the income from the no-brainer audits of plans with 200 eligible but only 20 accounts balances. I also wonder what impact the auto enroll mandate will have since we will surely see an increase number of participants with a balance.

This wasn't a total surprise. This has been on the map since the proposed 5500 revisions in 2016.

Indeed they did! ARA GAC was one of the stakeholders pushing this after LTPT in S 1.0, so I count this as a big win for our advocacy folks. Its not always instant results, but this is big one. We have plenty of plans that will drop out of audit because of it.

Practitioners and industry organizations are really the ones who have pushed e-filing of the 5558 (for good reason). IRS has had a "we will get to it when we have time and funding" approach...

As sad as it is, this is probably dead on. The notice generator automatically generates and mails out a notice when certain data or criteria are met in the system. Unless its a glitch, someone found and entered an old 5558 into the system and a notice was mailed out.

I think you are making this more complicated than it needs to be because of how you define participant. I would go back to the plan document. Are you sure none of this is spelled put in the definitions?

They are (if there is a balance), just not entitled to future contributions.

This.

I sure hope so...

Yea we were caught off guard by it as well...

Impossible. That would mean that Lorena filed with Marty's super secret pin...

Me too! @Jakyasar I agree with David (and Derrin) on the compensation issue. I would use $22,000. Its worth pointing out that there is no formal guidance on losses in a related business, so the question should be "is this approach reasonable?"

I think you hit many of important questions here. I agree that it would be income rather than compensation, so it will not affect plan compensation or payroll taxes It makes sense to tax in the year of contribution rather than the year of allocation. Otherwise you could run into issues where the contribution is decided on months after a participant files his or her taxes for the year of allocation. Plan assets for withholding... probably limited to instances where the participant is otherwise eligible to take an in-service distribution to prevent leakage.

No permanency issue with merging new plan into existing plan. The new plan "continues" in the existing plan because of the merger.

I have seen a few people raise the question. I don't see why FICA would apply since it is a payroll tax. Match and nonelective contributions as Roth is more like a Roth conversion. Its a pre-tax contribution from the employer that the employee elects to treat as Roth. The employee has to include the amount as income, but it isn't compensation.