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?

I see that WEB CE does EA. But I don't see any ERPA. I think that EA credits count for ERPA CE. And that would punch my ticket. But I would like something that is a useful review. Do they have anything on retirement plans?

What have people found besides Sungard and ASPPA conferences for CE credit?

Thank you Mike. Participant went into the website of the Investment company and changed his pretax deduction from 10% to 2%. This was not picked up by payroll for 2 months, December and January. So too much was deducted from his paycheck. He wants the money. Should the excess be forfeited as a mistake of fact and the Participant made whole outside the plan? Should it be distributed to the Participant as an excess with the Plan issuing a 1099?

A Participant went on line and changed from 10% to 2%. Should the excess be forfeited as a mistake of fact and the Participant made whole outside the plan? Should it be distributed to the Participant as an excess with the Plan issuing a 1099?

.

This is my question today. Can anyone help me?

Let's say it is June and we see that we missed a deferral election for 4 months. The missed deferral was $2,000. The correction will be 25% or $500. Will the $500 QNEC be counted in his 402(g) limit for 2018?

Employee went on line at investment company and made a positive election to have a Pretax deduction of $100 per pay, starting 10/1/2016. Some how this never went to our payroll system. We just found it last week and started deducting 2/23/2018. I think the QNEC correction would go like this. 50 percent or $50 per pay from 10/1/2016 to 12/31/2016. 25 percent of $25 per pay from 1/1/2017 to 11/30/2017. Zero for the last 3 months, 12/1/2017 to 2/23/2018. What do you all think?

I think CuseFan has hit on the problem. It won't pass testing using 100 % of TWB. And since it is not in the plan, accept by 11(g) amendment, I don't think it qualifys as a design based safe harbor.

Bird is that supposed to say after 12-31-18?