ElaineW

There is a plan where the existing document is profit sharing only- it does NOT include 401(k) provisions. Well, last year they made deferrals, and according to them, they have W-2s showing deferrals. I believe based on there being W-2s showing deferrals, there was an intent for the plan to be amended to include deferrals, but that was not done. Can the plan be amended retroactively to reflect the way it was operated and would this also have to go through VCP?

If there is over 5K for a missing participant in a non-PBGC covered defined benefit plan or cash balance plan can it be rolled over?

A covid distribution was processed by the TPA without the trustee’s authorization. Are there penalties/consequences? What should the TPA do?

There is a 401k plan that allowed for rollover contributions. It was restated & amended about 7 years ago and the permitted rollovers was switched to “no” but every year since then there have been rollovers into the plan. Can a retroactive amendment be done for this or does it need to go through VCP or self correction?