RatherBeGolfing

Depends on the firm. Most places have a set rate in their service agreement for ad hoc services like this. Many places waive fees for things like this in favor of client retention. My guess is that very few TPA have "rates" for different positions. I did when the TPA was connected to a CPA firm, but TPA firms usually do not track billable time like a CPA or law practice.

Its hard to tell when the only ones you hear about are the denials. I have had both denials and approvals in the same batch in prior years. You should be able to get a resolution, but its a time suck.

self-certification appears nowhere in the statutory language, but the IRS included it in FS-2024-19 https://www.irs.gov/newsroom/disaster-relief-frequent-asked-questions-retirement-plans-and-iras-under-the-secure-20-act-of-2022 See Q&A 11 Q11. May a plan sponsor or plan administrator rely on a participant’s reasonable representations that the participant is a qualified individual? A11. A plan sponsor or plan administrator is permitted to rely on a participant’s reasonable representations that the participant is a qualified individual who qualifies for this special treatment for distributions and loans, unless the plan administrator (or other responsible person) with respect to the qualified employer plan has actual knowledge to the contrary.

Thanks @Belgarath!

I appreciate it Craig. Stay dry on the east coast, we are bunkering down here in Tampa.

Thanks @xabana!

Thanks CBZ, I'm leaning towards this as well since I dont see any reference to the type area designation.

Thanks CBZ, this is all I have seen as well, other than a reference to Katrina Relief in Notice 2005-92. Again, I cant put my finger on it but Im pretty sure we were always limited to areas designates for individual assistance. I just happen to have a participant in a county that qualifies for public assistance under TS Debby, but they did not qualify for individual assistance.

@Craig Hoffman I haven't seen any for my clients yet, but I know there were erroneous denials dated 9/16 that have been talked about previously. Edit: We did get a denial dated 9/30/24, but it was for a 8/31 due date. 5558 mailed on 8/23/24.

I'm having a hard time finding a good source for when a disaster is a Qualified Disaster for purposes of Qualified Disaster Recovery Distributions. Im 99% sure that for prior disaster recoveries, it was limited to areas FEMA designated as eligible for individual assistance rather than only public assistance. Does anyone have a good source to confirm or refute that only areas designated for individual assistance qualify? I think this will come up rather frequently for those of us with clients in the southeast. Next hurdle is whether the participant is a qualified individual, but we can clear that through self certification... Thanks!

Its plan design. The plan is safe harbor regardless of any actual deferrals and match contributions.

100% agree.

Yes. Its not "could file an EZ", its required to file an EZ. If you are required to file on an EZ, you cannot file an SF. Almost. You have to mark it as "First return/report". And be prepared that you could receive a letter from DOL or IRS asking why the first return does not line up with the plan effective date. No big deal, you just tell them you filed EZ before. Is the plan covered by Title I?

At least we should get Secure 2.0 technical Corrections now that there is something to attach it to...

SF as long as they meet the normal requirements for a 5500-SF over a 5500 with Schedule I, such as eligible assets.

Great point Ilene!

This happens all the time. I have never had the IRS follow up on a final EZ with $0 BOY assets.

That is how I read 8(ii) as well.

So no other adjustments in the AA or BPD? What is the difference between W-2 + elective deferrals? I bet its 125 pre-tax deductions...

RTFD. I'm sure the document says more than just W-2 comp. All document provisions regarding comp matter, not just W-2, 415, etc.

Nah, I don't see the point to be honest.

I agree with @Bill Presson as far as credential is concerned, but I am not aware of a requirement to have the prior credential to take the exam. In other words, you can take the exam before you have the QKC designation, but you can't apply for QPA without having met QPC. I took the exams out of order before there was a QKC designation, but this was back in the hunter-gatherer days...

Im aware, I was pointing out that the DOLs position is that you have to file with DOL, not IRS, if you want to use the calculator. The OP stated " I know some will say you cannot use the DOL calculator unless you file with the IRS", which is incorrect.

This is the answer. And it is impossible for us to guess if earnings should be considered without knowing what the DRO says...

The DOL says you cannot use the calculator unless you file VFCP (DOL not IRS).