RatherBeGolfing

Same here. It is reasonable for many of them to do it on the payroll date, and it it is pointless to make the correction process longer (especially if the client is paying for the time) when the difference is in pennies.

Eh, I'm going to disagree. If you do not have reliance on the safe harbor, its back to earliest date when it could have been segregated from employer assets. You don't get the 7 days as a freebie if you don't qualify for the safe harbor.

I think the "requirement" OP is referencing is how many investment folks explain 404c diversification requirement. That one alternative should be for capital preservation, like a MM or SVF.

https://www.tdameritrade.com/retirement-planning/small-business/individual-401k.page TDA calls it a "complete individual 401(k) Kit" with an adoption agreement, BPD, and application for investment account. @Blue_Sky does that sound like what you collected and filled out?

Some financial institution "documents" usually consists of a short "fill it in yourself" adoption agreement with references to a BPD and opinion letter, but I have never seen someone with an actual copy of the BPD to go with their AA. It could be that short with TDA, but it also might not be.

If you work with an investment advisor, CPA, or attorney, you can ask they have Third Party Administrator (TPA) they work with or can recommend.

Why? There is no benefit to maintaining two one participant plans.

Thanks for this, it gave me an excuse to go down the rabbit hole to look at why they are different and why limits are adjusted using different indices. I do love some history of the Bureau of Labor Statistics with my coffee...

Thanks Mike! We are cobbling together the full picture here ?

At first thought, it seemed off. But, you are talking about such a short loss period that an extra day is a significant increase. If it is 4 days late and you add 1 more day, its a 25% increase. If it is 104 days late and you add 1 day, it is less than 1% increase. The math: 4/30 is $2.13 5/1 is $4.27 5/2 is $6.40 5/3 is $8.53 5/4 is $10.66 5/5 is $12.80 5/7 is $17.06 5/15 is $34.10 Counting 4/29 as a day in the loss period: Amount doubles from 2 days to 3 days (2.13 to 4.27) +1 day Amount doubles from 3 days to 5 days (4.27 to 8.53) +2 days Amount doubles from 5 days to 9 days (8.53 to 17.06) +4 days Amount doubles from 9 days to 17 days (17.06 to 34.10) +8 days The amount due doubles as the number of days late you add to the prior number of days doubles.

don't have it handy at the moment, but there is the IRS memo from 1998 that says it shall be in writing. I don't believe it says before, and we can probably come up with 20 reasonable interpretations of "written"

That really isn't the concern either, they are fine with you raising your prices. They might be a lot more concerned about prices going down. Theoretically, if your competitor charges X and you raise your prices from X-2 to X-1, someone else will step in and charge X-2 (as long as you and your primary competitor does not control the market). You raising your prices slightly isn't anti-competitive. On the other hand, If you and your primary competitor "collaborate" and decide to lower your prices to X-3 and X-4 (and keep them there), you might be able to gain a significant share of the market without cannibalizing each others customer base. That would be anti-competitive.

$999,999 Race to the bottom and all that

Good point.

Don't we? There is nothing in the statutory language that would support making them "untouchable" by an otherwise proper exclusion.

Must....grind....out...few...more....years decades...before....retirement!!! ?

I'll play along Its (mostly) exempt from ERISA because there are no employees to protect. It would be odd to then exempt it from the rules that dictate when employees must become eligible to participate. Unless I have missed something, the LTPT rules will apply, and will turn many of them into former solo's.

It is not.

Agree with both answers above.

DOL said back in 09(?) that you need to get a new one signed each year, and I believe that is still their position. We get one every year. I don't see a liability or a problem with an evergreen authorization though. You still need the signed Form 5500 from the client, so you can assume that they reviewed and approved when they signed.

If it was me, I would make it a three source split going forward: 1. Pre-2020 deferral and profit sharing 2. Deferral 3. Profit Sharing You can always explain why you can't track pre 2020 contribution, but you should track the contributions you can.

Agree with @Bird. Cash basis - No. Accrued - Yes. I dont think the IQPA will go along with not listing it as a receivable since it is the only way the numbers will balance. The explanation and reasoning for NOT listing it as a receivable on an accrual basis is likely more complicated and more work than fixing the 5500.

8/31/2026. Good catch. There is chronological issue with this argument. Per the CARES Act, in order for a payment to be delayed/suspended, it has to be due during the March 27, 2020 - December 31, 2020 period. Therefore, the argument that the loan is not entitled to add 1 year to the maximum loan term because payments were never due fails. The only way I see a loan miss out on the extra year is if the loan, by its original terms, does not have a loan payment due on or before December 31, 2020.

This was cleared up in Notice 2020-50. You get to extend the amortization period by a maximum of one year, regardless of how long payments are suspended. For OPs example, the latest extended due date is 8/30/2026 8/31/2026.

Still active as far as I know, at Faegre Drinker