Pam Shoup

My concern would be the "Immediate and Heavy Financial Need" part of the hardship test. If the hardhsip occurred two years ago and the person has been making payments, I would not consider that a hardship.

We have used a local high school Spanish teacher for translation services for many things. We use the built in translator in word for a bulk of the translation and then have the Spanish teacher clean it up from there. We contract the service by the hour. You could contact a local high school, college or a tutor and probably find someone who would be willing to freelance and do translations. Relius does provide their website, app and VRU in Spanish, but we have not seen it with their plan document software.

Maybe it is time to recommend that he switches to a payroll company that can send the data to the recordkeeper automatically. Then he can setup with the recordkeeper to "pull" the contribution dollars and process them. For example, we have a lot of plans that get paid on a Friday. The payroll companies either send us the data directly or email us to go and pull the data from their "TPA Portal" on the day the payroll is processed in their system (usually Wednesday or Thursday). Dependng upon the employer's preference, we then order the money from their checking account on Friday (pay date) or Monday to be deposited to the trust company and processed from there. Another advantage is that the TPA could be setup to access the portal at the payroll company. Wage and census data can then be pulled for enrollment and plan testing purposes. I know that he is a small company but there are several payroll companies who provide "TPA Portals" at no extra charge. These portals can usually be made available to all of the benefits providers for the company (with permission from the employer).

Since the plan is terminating, the participant will have a Qualifed Plan Loan Offset. They will have up to the due date of their tax return (plus extensions) roll the loan amount. https://www.federalregister.gov/documents/2021/01/06/2020-27151/rollover-rules-for-qualified-plan-loan-offset-amounts. You are correct, the particpant will receive a 1099R for the regular rollover and another one for the QPLO, reflecting that the loan qualifies for the QPLO rules.

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I agree with @Bill Presson. If an employer does not want to make employer contributions, and otherwise shows no inclinition to be involved with anything related to their plan, especially plan design, then that is a recipe for a plan to fail. Someone has to make the employees aware of the benefits of saving for retirement and there is only so much that can be done with technology.

We post the plan documents on the website for the plan sponsor/financial adivisor and the SPD for the participants/sponsor/advisor. We also post the last three 5500 forms and the annual plan testing for the sponsor/advisor and the SAR for all parties to the website. We then direct them to the web to find the data.

This is correct. You set up the loan payment dates as normal. In this example, if the loan is taken on 9/1/2020, the original 5 year payoff date would be 8/31/2025. The first loan payment can be delayed until 1/1/2021. The loan interest from 9/1/2020 to 12/31/2020 is calculated and added to the loan balance. The total loan balance (including interest) is then re-amortized to a payoff date that is one year past the original payoff date (8/31/2025 plus one year is 8/31/2026).

1. What's the point of hiring a 3(16) if you are just going to override them? 2. If I am the 3(16) and the PA has overriden me, I have a co-fiduciary liability that probably puts me in a bind, which then opens a whole other can of worms . . .

https://www.lifestatus360.com/solutions/ We use them for both addresses and for the Death lookup. I find that the quality of their data is pretty good.

I agree with you. MEP/PEP is not a solution for a lot of plans and I would not want to try to run one without a lot of software, programming and experienced staff. Luckily for me, I have a group of recordkeeping employees who have been with me for close to 20 years and they hate to do anything manually. We have our own custom written software that we use to manage our plans and our own IT department. Our rule is that if you can think of a way program it, request the programming! We have a "button" to do most everything and there is very little that is manually processed. We do use commercially produced software for trading, etc. but our backbone software does all of the data scrubbing and exports to the other software. It has been a huge investment but it means that we can be really flexible going forward. Our biggest growth is in the area of working behind TPAs who do the plan documents, 5500 and plan testing and we do the fiduciary recordkeeping on an open architecture platform. It creates the flexibility for the 3(21) or 3(38) to have 25,000+ investment options available and still allows the plans to stay with the TPA that they really enjoy.

We have a lot of controls in place at our firm and we have an annual SOC 1/SSAE-18 audit done of our recordkeeping and our fiduciary services. For the MEP plan, we are responsible for pulling the data from the payroll companies and ordering the money from the company bank account to be sent to the trust company. If the data feed is not at the payroll company or the ACH pull is not processed, we are on the phone immediately to rectify. If a plan is a continual problem, the proposed PEP rules gives us a way to spin that plan out to a stand alone plan. Software and programming is key here so that we are not manually tracking payroll dates. We are directly integrated with several different payroll providers so for a lot of the sub plans, the data is fed to us directly from the payroll companies. Fortunately, we have our own programmers on staff so we can have our programmers talk directly to their programmers and work out the direct links. Getting direct feeds also means that we get census and payroll data every pay period which is huge. In order the make the MEP efficient, we have to require that the employer use a payroll system so that we can get data electronically. We can't spend the time hand keying anything and it cuts way down on the errors. It also means that if the employer can get the data into the payroll software, we can get almost everything we need directly from payroll, without having the employer report it to us separately.

We have an open MEP that we will be converting to a PEP and we operate in most states. With that being said, we have spent the last few years setting up a partnership with us as plan sponsor, recordkeeper and Plan Administrator, an outside 3(38) and an outside 3(16) administrator. We have several 3(21) advisors that sell into the plan. We have invested a lot of money in software, employee credentialing and ongoing education (personnel, advisors and employers) to put it together. There is a market for these types of plans, but it is not a solution for everyone. If you have an employer that wants almost no inolvement in the running of their plan, they may be a good candidate for a PEP. Ideally, if the employer uses an outside payroll vendor with a portal (180 or 360) where we can pull data from and push data to their payroll vendor, it becomes an even better candidate. In addition, we require an auto enrollment feature for each sub plan in the MEP. We are an open architecture recordkeeper and our software allows us to roll up the data for some purposes and break it down for other purposes. www.automep.com

In simpliest terms, a plan where the balance is struck for each participant every day that the financial markets are open is a daily valued plan. Participants usually have access to a website where they can view their balances, make trades. etc. The service provider will also issue reports at least quarterly for each participant showing their account balances by fund and by source, as well as some sort of summary of activity. In an annually valued plan, the service provider will strike a balance one time per year per participant and issue an annual statement for each participant. There may be statements produced by an investment provider on a monthly basis, but the full valuation is only done annually.

Did you go into Utilities>System Admin>Mail/Proxy Setup and enter an email address there?

Newkirk was sold to DST, who then got sold to SS&C. You may also want to try Broadridge/Forefield.

I'm not Peter but I just want to offer up a caution, if the PARTICIPANT suffered a loss of income, they would be a Qualified Individual and thus able to obtain a Coronavirus related loan or distribution (if permitted by the plan). However, the CARES Act does not currently extend this to the spouse. Further guidance is needed. For the hardship withdrawal, not all plans permit hardships for Federally Declared Disasters so a quick document check is in order.

http://www.erisapedia.com/webcasts Erisapedia also has free webcasts that qualify for ASPPA/ERPA credits. They have four classes (five hours) that you can sign up for right now.

Without discussing IF this should be done, there are two ways this can be handled. The first way is through the use of fund models, that are a "Fund of Funds" which are available in the plan. The available software for this is clunky and we have a few plans using this approach (in conjunction with allowing participants to choose from the underlying funds), but we will not be adding any new plans. The other way is through the use of a "fund" setup on the trading house platform. The investment advisor chooses the underlying funds and does the trading, and the share prices are reported back as it's own CUSIP. MidAtlantic calls it ModelXchange and Matrix uses Model Toolkit. The underlying investments in these models are not necessarily investment alternatives available in the plan. The plans have a variety of other investment options available, including the model funds. There is some additional costs to run the models, but we have several plans that use them. It also comes down to what the broker-dealer of the RIA will allow them to do too. The RIA also needs to be involved in what is reported on the plan's 404a-5 notice, etc. There is a lot of liability for the RIA so expect to pay their fees accordingly. I do not believe that a plan sponsor is able to run these funds directly.

You may want to look at NTSA (sister company to ASPPA) and the TGPC designation.

On a personal note, as a person who got back into the dating pool after being divorced for 10 years, I quickly found out that you can find marriage and divorce records online for almost any county in the United States, because people tend to "Fudge" the details about marital status . . . .

Yes discretionary. We will be recommending to plans that already to have a loan provision to add the Caronavirus loan provisions. For the Caronavirus distributions, this comes more under the inservice rules so for those plans that currently permit inservice distributions, we are recommend that they permit the Caronavirus distributions.

We have had some of these conversations, mostly with doctor and dental offices. Another question that is being asked is about loan payments for laid off employees. These next few months are going to be a roller coaster ride, that is for sure!

I agree with shERPA. If the TPA is just doing compliance testing and the employer does not want them to test for 2019 (as an example), then the employer should just make it clear to them that they do not want them to test 2019. Keep in mind though, you may be referring to a billing issue and not a work issue. If the TPA has been providing some services during the year (like sending out distribution paperwork, calculating vesting, etc.), then they should be compensated for the year if the TPA did perform the work as expected when the work arose. You may want to check to see if the TPA bills in advance or arrears. On the other hand, if the TPA is involved in recordkeeping services, and perhaps doing daily valuation, then a longer time frame is expected for the transfer of those services.

From a recordkeeper's point of view - check to see if whoever holds the plan assets can work with ACHs or wires and eliminate the paper check processing altogether. The recordkeeper may be able order the ACH directly, once the contribution data has been received.