metsfan026

Trying to determine if a potential new client is an Affiliated Service Group. I don't think it is, but I wanted to be 100% sure: Client is a management company, working with 40+ different affiliates. While they have an ownership stake in each one, it is far less than the requirement to be a Controlled Group, and each individual affiliate has a different owner. They perform management functions for each one, but obviously with more than 40, no one affiliate represents at least 50% of their functions (nor does it satisfy the receipt test) From the way I'm looking at it, it wouldn't be considered an Affiliated Service Group but I wanted to be 100% sure. Thanks in advance!

So we taking over a Cash Balance Plan that's terminating and distributing the money to the participants (2 owners and 1 employee). It's a non-PBGC Plan. The Plan is fully funded, and also has a credit balance displayed on the previous SB. My questions is, how do we handle the Credit Balance on the final SB? Is it still displayed, even if all of the money is distributed from the Plan? Should the assets be distributed, with an excess given pro rate to the three participants? I just want to understand what the process is so I can help out. Thanks in advance!

I know the Gateway for plans being tested together (Cash Balance & 401(k)) is generally 7.5% (but it's not required). My question is though, does that 7.5% include the Safe Harbor if it's being done? We are now installing a Cash Balance Plan, but there is an existing 401(k) Plan that is already giving a 6% Safe Harbor. So, I wanted to make sure that to satisfy the Gateway we only needed to give an additional 1.5% into the Profit Sharing? Thanks in advance!

This is the first year that we have plans utilizing the option to make a Mega Backdoor Roth, so I want to make sure we're displaying the mega backdoor roth accurately. Is the money put in just lumped in as an employee deferral? Thanks in advance!

Thank you! Is there anything in the regs that I can reference? I just want to be able to back it up to settle it. Thanks!

I;m having a disagreement with someone regarding this: Once a loan is taken, obviously it can't be more than 50% of the vested balance (up to $50k). What happens once the loan is taken? Does the 50% still stand? If a participant with a loan then wants to take an in-service distribution (as allowed by the document), can they not take it if it brings the loan balance to be greater than 50% of the balance (i.e. if someone who is eligible opts to take 100% of their balance, leaving the only current asset as the loan balance)? I've been told by a record keeper that the 50% rule no longer stands once the loan is taken, but I wanted to confirm. Is there anything in the regs that I can cite, if I'm correct? Thanks in advance!

I just want to make sure I'm understanding this right, as I just help out with certain clients. We have a client that froze it's Cash Balance Plan as of January 1, 2025. So, the facts (I believe): 1) The Normal Cost for the year is $0 2) The Amortization Schedule is negative 3) The assets are slightly greater than the Funding Target Under this scenario, is it accurate that no contributions are owed for either plan (the Profit Sharing becomes discretionary I believe)? Thanks in advance!

So would it be prudent, for a 12/31/25 plan, to use the December '25 rates and indicate 0 for the month? I just want to make sure I understand

Previously we had been using the rates from the Funding Table 2A (Post-ARP/ILJA 25-year segment rates) for our calculations. This year it was: Tier 1 - 4.75 Tier 2 - 4.81 Tier 3 - 5.50 However, I believe those rates are no more (or maybe I'm wrong). What are we supposed to use in their place? Thanks in advance!

What I've always done. Thanks!

Having a debate with someone in my office. For the participant count on the Form 5500, if someone becomes eligible do you include them for the Beginning of the Year count (for Active and Total Participants)? Or do you not, so the number of participants at the beginning of the year matches the number for the ending of the year of the previous Form 5500? I know it's minor, just want to make sure. Thanks!

We have a plan that's suddenly terminating in a few weeks. One of the participants have an outstanding loan that they want to payoff, prior to taking a distribution. Does that have to be done prior to the Plan Termination, or can they pay it off via personal check a few weeks after the Plan Termination date? This is one I haven't run into before. Thanks in advance!

The document includes it, but the client says they didn't pay any. So the total salary is under the HCE so that what it is? I just want to make sure I'm understanding

This is a situation I've now encountered, so I wanted to check. - Participant has no ownership stake in the company. - In 2023 they made about $200k, therefore they were considered an HCE in 2024. - In 2024 the participant missed several months due to being on active military duty, thus earning about $75k So, my understanding is that for 2025 they would not be considered an HCE. Is that accurate? Thanks in advance!

We have a few Plans that were adopted in February or March of 2026, as of December 31, 2025 (as allowed under Secure 2.0). Should we be filing extensions and Form 5500 for these Plans? I know under Section 201 of Secure 2.0 it technically isn't required, or is that just for Plans adopted after the extension date? I don't want to miss anything, or file an extension if we aren't supposed to. Thanks in advance!