truphao

not "may be" but "highly likely"

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.

post-mark (either physical or electronic) governs.

How long did it take the PBGC to make the determination?

I am voting for 120K as well, but please refer back to AA regarding inclusio/exclusion elements.

a small independent pharmacy. Is it a subject to Title IV or not?

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

I think Lou is correct unless there is a special exmption for 403(b)s which I amnot aware of.

I love this "re-terminating the Plan" terminology

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.

yes, but watch out for minimum TH requirements (if the Plan is TH).

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.

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.

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.

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?

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.

which are the platforms that focus on micro plans?

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.

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....

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).

which can be amended if needed as long as the prior method is protected for 2024....

Your TPA is correct. Keep in mind that 25% of compensation limitation includes the match as well. This is not DYI exercise, the results are driven by demographics and thus will be unique to your company. The best outcome meeting your objective should be analyzed by your TPA and include at least a couple of alternatives. My recommendation would be to invest heavily into improving the communication process with your TPA or find another TPA which would make you feel comfortable.

We are in the same boat - trying to restate a few DB plans using ASC - but have not really started yet. Would be happy to exchange opinions in a couple of weeks.

maybe, if you demonstrate the compliancewith (a)(26) using annual method, then, yes, there is an issue. If you can demonstrate compliance with (a)(26) using accrued to-date method, then it is OK (quite often it works for the year of plan termination).

we explicitely allow for conversion of VAT at age 35+ to accomodate Mega Back Door. This is for solos.