Loves401(k)

Does anyone have a suggestion for fixing ADP Refund for 2017 done by prior TPA in May and then done again in October? 2 people were paid out twice.

LOVE IT!!

Was it actually a loan?

And you may be able to deduct some of the medical bills

Let's use the example of someone electing a 5% deferral rate on Wednesday April 11th. This pay period is from Monday April 2nd through Friday April 13th. Is it legal to do the 5% deferral on the pay check for this period that will be paid next week?

It sounds like you are correcting the the IRS tells us to (EPCRS) Can you clarify your question about it being a employer contribution?

This brings up another question. If there is a market loss, is it legal to reduce the QNEC for losses?

Just to clarify, I am really talking about the IRS accepting or not accepting the DOL Calculator. Specifically, in the case of missed election forms that increase a deferral rate. So we actually know the investment choices of the Participant.

Has anyone had the IRS not accept the Dol calculator since EPCRS REV PROC 2016-50?

Good Point ! I did notice that when I reread the paragraph. And that is what I am struggling with now. I can tell the investment platform to calculate the earnings. But I will not have anything to show someone, to prove it was done correctly. I am not comfortable with this. Thoughts anyone?

FWIW REV Proc 2016-15 EPCRS on Page 31 paragraph a - under reasonable estimates allows the DOL calculator. "For this purpose, the interest rate used by the Department of Labor’s Voluntary Fiduciary Correction Program Online Calculator (“VFCP Online Calculator”) is deemed to be a reasonable interest rate. The VFCP Online Calculator can be found on the internet at http://www.dol.gov/ebsa/calculator."

If we miss an increase in deferral, we put in a QNEC for the missed deferral plus a QNEC for earnings. My question is about calculating the earnings. We have always used the DOL Calculator. Is this what everyone else does? Are there any times when actual investment returns are required? How about if the market drops? Are we allowed to put in zero earnings if the actual investment return was negative?

TPA

yes. Draw is irrelevant.

I spent a long time on the phone with Voya, JH and Transamerica, and could not find anyone that knew of anything. Could someone provide a contact?