acm_acm

Whether 204(h) applies or not, doesn't it make sense that you would tell the affected parties? I would be interested in the communication strategy for telling the affected parties (likely) a year later when the don't get a PS contribution that they had been excluded, but were only being told after the fact.

HRAs, HSAs and FSAs can generally be used to reimburse the participant's eligible expenses and those of the participant's eligible dependents (spouse and/or children). As long as the document you use to establish the RO HSA is worded correctly, you should be fine.

I thought that any borrowing by a qualified plan (other than an ESOP) was not allowed. I worked on a small DB plan where the owners held the money in a brokerage account and bought shares using margin. That was a no no and generated some kind of excise tax penalty. I can't cite the chapter and verse right now, though.