EMoney

If plan is not on a recordkeeping platform, use PenChecks for plan distributions that require withholding

If you choose the print option and then choose the "Other" tab, there is a "Company List" option. That report provides much of what you listed.

Sounds like a plan that should not allow participant loans!

In the ERISApedia Grab Bag webinar, the presenters specifically said that adding deferrals to a profit sharing plan was not a grandfathered plan so auto enrollment required.

I'll take the under on the .01% good:) In all seriousness, the situation you outlined is the only potential positive I can see in the LTPT rules. Other than that. LTPT is an absolute nightmare from an administration standpoint and plan sponsors are not going to do it correctly. The eligibility rules are far more complicated than they need to be--if all you had to do was determine if the employee in question worked 500 hours in the plan year for 3 (or 2 starting in 2025) consecutive plan years, it would be mostly doable. But these eligibility rules are insanely complicated IMO. If I feel that way, how is a plan sponsor supposed to understand them?

Unless I misunderstood, during the ERISApedia Secure 2.0 Grab Bag webinar, the speakers indicated you could add profit sharing back to first day of the year. However, they also indicated you could not add an additional plan (i.e. CBP). Anyone else hear it that way?

Are there any local TDA (now Schwab) offices in your area? In recent years, we came across an advisor in a local TDA office and working with him has made our life much easier when we need things done (i.e. statement copies, distributions, etc.).

I think the question is did the employee work 500 hours from 10/4/21 through 10/3/22? If yes, that is first YOS for LTPT. If document switches to plan year, then 2022 becomes second YOS for LTPT.

I read an article last week on the daily BenefitsLink Retirement Plans newsletter. It was written by a law firm and indicated that the plan must count hours for LTPT purposes in the employee's first 12 months of employment and then can switch to plan years beginning with the plan that starts in the year the first employment year ends. If I understand correctly, that means you need to determine if your employee works 500 hours from 10/4/21 through 10/3/22. If so, there is one year. If your eligibility computation period shifts to the plan year, then you look at 2022 so you potentially have two years for LTPT purposes at the end of 2022 even though the employee did not work 500 hours in 2021. In 2025, when LTPT rules only require 2 years of 500 hours, an employee could easily get 2 YOS for LTPT purposes when they completed barely over 12 months of service. I think this logic makes it far more complicated than it should be (it's already complicated enough). I hope the law firm is wrong but I doubt they are. Anyone have a different interpretation? It would be much easier to simply determine if an employee had 500 hours in a plan year and credit on that basis. Just one more thing SECURE 2.0 is trying to make overly complicated IMO.

Good comments. Also, if you keep the receivable loan payment on there, you would reduce the overall loan balance by the principal portion of the payment, not the total loan payment. Perhaps that is what you meant but not how I read it.

What's wrong with letting them participate in the year(s) they are NHCE's? The plan won't fail the ADP test if they contribute when they are NHCE's.

We use Relius documents (PPD version). In one of their document seminars, they went through a similar situation and described months of service as simply a passage of time. So, if an employee was employed on the entry date, they entered on that date regardless of how many times they may have been terminated and rehired. If that is the case, I think both of your examples would result in an entry date on the rehire date. (Of course, other documents could be worded differently.)

Allocation of fees is a fiduciary responsibility. How would your fiduciary decision maker feel arguing he or she allocated 20% of a participant's account balance to fees? If it were me, I would not want to make that argument to any governing body. I've seen a client do it, though, and he was HCE/key!

CuseFan, I agree with you. My premise is more along the lines of a plan sponsor taking an in-service distribution to avoid the $250,000 in assets so they don't have to file an EZ. I've seen that happen and then they think they don't have a 5500-EZ filing obligation or a need to terminate the plan when they decide they no longer need the plan.

I agree with this.