truphao

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.

agree, it could have been done at Plan's inception but not now

No CG but watch out for potential ASG issues if businesses are "overlapping". Yes, employing a spouse would solve 401(a)(26).

I believe life annuity payments are exempt under 72(t). Furthermore, payment to safety public employees are explicítely exempt if over age 50. https://www.irs.gov/retirement-plans/substantially-equal-periodic-payments

my vote is 9/30

Because when it gets complicated, it's always the actuary who should know, no matter the subject . However, this one clearly falls under the purview of a CPA.

Thank you Peter, well explained.

Is the Beneficiary desigantion form required to be notarized if the beneficiary is a spouse? Is it even needed for all practical purposes? Our plan docs name spouse as a default beneficiary in the pecking order. Interested to hear thoughts and opinions.....

I believe "eligible employee" means "non-HCE" only, which would preclude the owner. Speaking form memory, would need to go back to the law.

yes, thank you - had a total balckout on this one.

S corporation, two owners - father and son, both are 50% shareholders, no other employees. Is 5500-EZ or 5500-SF required? In prior years EZ was filed but I do not think it is correct and SF is required? Anything else that I might be missing?

here is a practical suggestion (given the limitation of being "uneditable") - I would not have a problem using a PV of benefit accrual using a reasonably conservative interest rate assumption (5.50%?, may be 6.0%?) as long as there is a footnote somewhere disclosing "this is for illustration purposes only" and "the actual value will depend on future interest rates".

exclude by employment classification if possible, impose hours to get an accrual, definitaly exclude pre-effective date sevice for vesting.

Restore or not is spelled out in your Plan Document/Adoption Agreement. It is a choice in the AA.

looking for ERISA attoney specializing in public sector reference, Oregon. You can DM if you prefer. TIA.