RatherBeGolfing

The tricky part for ERPA CE is documentation. It sounds like IRS is getting more strict on CE that is not reported to the IRS directly (like ERISAPedia does). I do have some other sources that I recomend for staff or ASPPA CE where you can just self report. Nova does a decent amount of webinars https://nova401k.com/webinars/

I think @thepensionmavens issue is that they don't have a copy of the documentation for the DFVCP application, not the 5500 itself. The DOL will send a confirm to the email address you list as the contact when you apply for DFVCP. The subject line of the confirmation email is "DFVC Program Confirmation of Attempted Submission". I normally use my email as the contact email for the application for this reason. There is an agency tracking number in the email, but if you don't have that, you should still be able to call the DOL and ask. The tracking number will start with year and month of the application, followed by six digits. So if applied today, it would be 25-08-XXXXXX. There is no public database for DFVCP applications.

@Peter Gulia Who does the admin on the plan? If there is a TPA involved, they would most likely be able to make that determination. We are already working on this determination for our clients. Our RK system does not have the self-employed indicator (as far as i know), but our testing/admin system does.

Good point. You CAN do it, but that doesn't mean that you should. FWIW, Im adding Roth and IPRR to all plans that allow catch-up.

You are correct. Prior to the proposed rule, a lot of people believed that in order to allow catch-up, you would need to allow Roth. I think that's where the confusion is coming from.

I agree with Bill, you would normally have a new plan for one of the companies since the other would remain the sponsor of the original plan. If you did two new plans, the old MEP would need to terminate and file a final 5500.

I agree, and I don't like the IF in that statement. I think you can argue that if there is no interruption or distributable event for participants, no harm no foul, as you SHOULD be able to dump an underperforming service provider. Some related issues: - Will a new provider (B) allow you to open a plan mid-year if they know you have one elsewhere (A) that you will discontinue? - Will A allow you to move funds even if contributions stop? If not, Participants have two accounts until they can be consolidated - Plan limits, B likely cant account for contributions to A - 2 year distribution restriction. Will B account for time at A? I think you can do it and defend it even if its technically wrong. Sounds complicated for a dang SIMPLE though... We have been doing a lot of SIMPLE to SH conversions, just saying...

For SIMPLEs - You can start one mid-year if you don't have one - You can start one 1/1 if you already have one - You can terminate mid-year if you replace with a SH 401k - You can terminate 12/31 (with notice) without replacing it. It comes down to: If the current SIMPLE is tied to the investment provider, can you change without terminating the existing SIMPLE and starting a new one? Im leaning no because SIMPLEs are weird...

Plan and plan sponsor also have to have the same tax year to rely on the automatic extension. Best bet is still to file a 5558

5500SF Part III 8b is other income, so gains/losses/dividends/etc. How did you get to $25,300? Can you "show your work"?

From what I hear we are expecting final regs, not another delay. I don't see it on the OMB Dashboard yet, so it may be a December surprise.

Amen Brother Bill!

Sure! There are tons of GPTs in ChatGPT and other AI apps. For example, there's an excel GPT in ChatGPT that is focused on excel, so your answers are going to be tailored to excel. I'm creating a few custom ones for my own use or internal use. For example, an EPCRS GPT. I have limited it to using the current version of EPCRS and my instructions (which are expanding and help narrow answers). It's still in early stages, but so far its a good way to find answers or the correct section quickly. Another one im playing around with is a Controlled Group GPT. Instead of feeding it all the data you think it needs, it prompts you for input. In a nutshell, the CGGPT starts by asking you how many entities you are working with. Lets say you answer "3" The next question it asks is how many owners between all three entities. After you answer, it asks about each owner's equity in each entity. And so on. The basic idea is to have the GPT ask you for all the relevant data instead of you asking it to make a determination based on the data you give it. The more prompts you pre-program, the more questions are asked. You can get super detailed or very basic. It's a fun process to go through (for us pension nerds 🤓) and hopefully you get a useful tool in the end. I also have another one I have started uploading different plan documents to and building instructions in order to determine where certain provisions are and how they are similar or different by vendor. I know of at least one company put there working on a document AI to help you map from one vendor to another. It's exciting stuff as long as you have guidelines you use it properly.

A recent reply to an old thread got me curious, what do you use AI/LLM ("AI") for in your practice, if any? Are you allowed to use it all? Do you use it internally or externally (with clients)? I have had this discussion in smaller settings, and I recognize that use of AI varies greatly. I'll start us off with some easy examples from my practice: - We do not use AI for anything with PII data, even if the workspace is locked down (not used to inform the AI outside of our workspace) - We do not use it for legal or compliance questions. I have seen many benefits adjacent professionals do this and the answers can be frightening. "ChatGPT said we are not an Affiliated Service Group" is a scary sentence... - We use it to review and revise communications. Don't like how your email sounds? feed it to an AI to make it easier to read, understand, etc. - We use it as a tool to help with formulas and macros for excel. - I am playing with it as an internal Q&A tool. By creating your own GPT, you can have the AI prompt you with questions (instead of asking it questions) and limit the source material it looks at to the specific documents you provide.

If a plan is subject to mandatory auto enrollment, you have to satisfy all the requirements for MAE in S2.0.

Don't forget that LTPTEs have to be auto-enrolled (absent affirmative election) if the client is subject to AE.

An employee is a LTPTE if the only reason they are eligible for the plan is because they met the LTPT rules. You are only required to offer the opportunity to defer, employer contributions are only required if they meet the plan's eligibility for employer contributions. If the issue is employer contributions, LTPTEs are not a problem since you don't have to provide employer contributions to them. There are two ways you can make sure you never have LTPTEs: - Eligibility for the plan is 500 hours or less - Eligibility is based on elapsed time.

Im not sure I see the issue. Eligibility is 1 year. Employee does not meet regular eligibility. Employee does meet LTPTE requirement. Why would the employee not be considered an LTPTE?

Since this thread is 20 years old, one can only hope that it has been resolved by now...

No. Remember, signing as preparer on behalf of the client IS the simplification. The default is the client obtaining signing/filing electronically with their own credentials.

LOL Indeed. Good catch

Nothing wrong with it as long as there is *no* quid pro quo. This is very common with smaller firms. You may want to consider what happens if the client does a bad job and you need to fire them... There are pros and cons to doing this.

Ok so you are importing it using a vendor upload. Are you doing a manual allocation of earnings, fees, etc and importing that using a vendor upload? Why not let FTW do that allocation for you? If you set up accounts and sources properly in FTW, you could have as many sources as you want and you would just enter the total for the year as a manual transaction. If you have a lot of participants you can import/export that data as well. Lets say you have 401k, Roth, SH, and PS. you have 1000 in earnings. let FTW calculate how much of the 1000 is 401k earnings, Roth earnings, etc rather than telling the system what belongs to each source. Does that make sense?

All of it. If it exceeds limits you have some corrections to do, and you those should also be on your 5500 for the appropriate year. You are scratching the surface of issues of SDBA only plans... You need more information to determine contribution sources, like a ledger or payroll report. The brokerage account isn't going to track it by source because that is not what it is designed to do. You need to do source level accounting of contributions, distributions, fees, earnings, etc. outside of the brokerage account. Do you have software that will do this for you? If not, are you an employee of the plan sponsor or advisor trying to do this without a TPA? If so, you need the assistance of a professional.

@Pam Shoup The guidance provides two correction methods: W-2 correction can be used as long as the participant's W-2 has not been filed or furnished to the participant In Plan Roth Rollover correction. The guidance includes a reference to previous guidance on In-Plan Roth Rollovers: With that in mind, I believe the answer to your question is Yes.