CLKent23

I have a client whose current recordkeeper does not charge any annual loan maintenance fees for outstanding loans. The client is now considering moving to a different recordkeeper, one which DOES take annual loan maintenance fees. For those loans already outstanding, is a fee disclosure to participants valid to then start charging annual fees to their loans after conversion?

Thank you both - this was my thought process as well, but wanted to be sure.

I have a current small client (approx 15 employees), with a 401(k) Plan with elective deferrals and is 3% Safe Harbor Non-elective Maybe. The client is deciding on whether to amend to Safe Harbor for the 2018 plan year, so that we can send the required 30 day notices ASAP. Question - the plan currently applies the SHNEC to ALL participants, but the client is considering Excluding all HCE's from the allocation in the future, which consists of about 4 employees besides himself. Can he make this part of the 2018 SH amendment and notify participants now that they the HCE's will not receive a SHNEC for 2018? Or must he wait and amend the plan for 2019 to Exclude HCE's from the SHNEC? Thank you!

Ok - I think I will prepare/send the forms and wait for the penalty notice. I can't find anything specific that tells me otherwise, so thank you for your input.

I just received an email from a client regarding distributions that were made from their plan in December, 2017 and need Forms 1099R issued. This is a plan that has the investments via brokerage accounts, which we (TPA) provide the recordkeeping for. We also produce the Forms 1099R each year, however the client never alerted us of these 2 distributions in January when we inquired. Now they want us to prepare the Forms, and I can see that there will be a penalty to the IRS for filing paper copies late ($100?). I've never experienced this, so does anyone know what the process is to file these late? Is there an addiitional form to file with the penalty, anything else?