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truphao

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Everything posted by truphao

  1. Form 5500-EZ instructions do not refer to "other qualified plans" but rather to "other plans maintained by...". SEP is indeed an indivudal IRA but it is established and maintained by a business entity.....My vote is to count the assets in SEP toward the 250K threshold...
  2. Thank you Belgarath, I am trying to convince myself that this is a CG so I do not have to go down the rabbit hole of ASG
  3. Company A, Father owns 50%, Son own 50%. Company also employs son's mother and son's wife. Company B is 100% owns by mother, mother and father are not married. This is a B/S CG, right?
  4. yes, if there is a cchange in both the firm and the actuary
  5. not sure if 204(h) is applicable to an Owner-only Plan. Although the regulations do not exempt Onwer-only situations explicitely but it is not an ERISA plan.
  6. not "may be" but "highly likely"
  7. if it is a DB Plan, then the question is "Why?" What are you trying to accomplish? If the objective is to increase the benefits for NHCEs, you can also accomplish that by increasing the benefit retroactively.
  8. post-mark (either physical or electronic) governs.
  9. How long did it take the PBGC to make the determination?
  10. I am voting for 120K as well, but please refer back to AA regarding inclusio/exclusion elements.
  11. a small independent pharmacy. Is it a subject to Title IV or not?
  12. this is a part of your Funding Method. The Funding Method includes the definition of the Entry Age, I believe all of those above are reasonable unless you get some wierd results (in actuarial sense) , then you should step back and re-evaluate. The best part is that you get to be an actuary again rather than a box-checker
  13. I think Lou is correct unless there is a special exmption for 403(b)s which I amnot aware of.
  14. I love this "re-terminating the Plan" terminology
  15. just not a thing. The backdoor approach is via doing in-service distributions to their 401(k) and doing Roth conversions there. Devil is in details.
  16. yes, but watch out for minimum TH requirements (if the Plan is TH).
  17. curious if there is any additional development on this subject. In particular, I am asking if it is OK to improve the benefit/Pay Credit for the Owner after December 31, 2024 and reflect the increased benefit in 12/31/2024 valuation for 404 purposes.
  18. let's not overlook that the Trust might have been already created when somebody (the TPA?) has apllied for the EIN for the Trust. Thus, IRS "might already know" about the Trust. I am totally with Lou regarding the codes of ethics and Standards of Actuarial Practice that certified actuaries must (and should want to) live by. This mess is really messy. I personally would not be comfortable touching this without an ERISA counsel. Regarding who is here to blame - this is definitely a client's fault for dropping the ball. Nevertheless, the TPA should have taken some action - IMHO. This sentense "The Administrator was under the impression that a 5500 wasn't needed until the assets got to $250k" highlights the issue.
  19. no AFTAP certifications for 3 years either - not sure if there are any practical implications or not (< 5years), but let's add this to the list for fun.
  20. It sounds like they signed the Plan Doc ("the paperwork"). Dittoing Lou why is it coming up only now? If Plan was set up it is the TPA duty to follow up with the "action plan". If that happened, and and it is the the client who dropped the ball and never returned phone calls/messages, the TPA should have resigned at some point. It is the time for lawyers to get busy. Maybe it is the time to stop "sell now, and we will figure out how to deliver later" culture at the big TPA firms?
  21. agree. Furthermore, althouth it is legal not to give an interest credit until the end of the year, as an actuary I have an issue with that. Seems like a loss of "economic value" to me, and I do not like it; we normally use a "pro-rata" approach.
  22. which are the platforms that focus on micro plans?
  23. Which issues? I was simply asking which vendors the practioners like the most nowadays. This is for a commodity-like product (401k SHM plan) which does not require elegant expertise of the TPA. Based on the criteria of cost and sevice with ephasis on costs.
  24. yes, while we are at it lemme suggest to modify BIS rules to be different hours for different sources. since we are going to calcuate every employee every year by hand anyway....
  25. what are the most practical options (cost first, quality second) to offer a fully bundled Safe Harbor Match (Basic formula) stand-alone 401(k) Plan? For a small company with 15-20 employeees (high turnover, bunch of part-timers).
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