RatherBeGolfing

This. Just like you are not supposed to have someone who is in the country illeagly on payroll, but if you do and they meet eligibility, you need to account for them.

Its really not. Yes it takes a bit of time and as @MoJo points out, you need to gather the documents to state your case. It is absolutely a better experience than a DOL initiated investigation though. For some reason I just don't buy that there is no note or referral if they have notified you of an issue and you choose to not accept the invitation. Is it voluntary? Yes, but you are on their radar, and that is not where I want to be.

A triple stack match usually has a three layers of safe harbor contributions. The first is a regular SH match, the second is a fixed match that meets the SH requirements, and the third is a discretionary match that meets the SH requirements. The first two are required, but the discretionary portion is an annual decision.

When I worked for a CPA firm, our policy was archive after 12 months and purge after 7 years for emails (unless we were notified of litigation, in which case those emails would segregated and saved past 7 years if necessary).

EZs are not published on EFAST, even when filed electronically.

Here is your Amen! @austin3515. And I agree, the vast majority of clients struggle with dual eligibility or less than straightforward entry dates, and will absolutely turn this into a huge mess.

The taxpayer can call the IRS to ask for the status. Practitioner can call with POA

Cool 👍. I still get a little mixed up without the Rev proc in front of me

I don't have the rev proc in front of me, but isn't there a notice requirement if you want to take advantage of the brief exclusion rule? From the OPs description they just started deferrals late.

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?