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Found 2 results

  1. I have a brand new start-up plan that started 1/1/19. The owner is just now calling me 12/11/2019 wanting to amend the plan to a SH plan because the company did well and he has extra funds to put to work (and not get taxed on). Obviously it is too late for that. And it is too late to change to SH for 2020. BUT... the owner is saying that his accountant, other attorneys and colleagues of his are saying we should be able to back date this and be able change the plan to SH for 1/1/2020 plan year. I can tell you that my Trust Co. and our TPA partner would never go for ever doing something like that. But since the feedback he is getting is that should be okay he thinks there should be no problem doing that, especially if each employee signs off that they received their SH notice. Thoughts/opinions on how to handle? His other question is something I do not know the answer to. He asked if he terminated his plan and went to another company and started a new Safe Harbor plan elsewhere - that would be effective for 2020 - would be allowed to do that??? OR if decided to terminate services with us and convert the plan to a new provider and changing it to a SH Plan - what are the dates and deadlines for that? Could he in fact do that and have it be effective some time in 2020?? Any feedback will helpful! TIA!
  2. I’m interested in learning more about how Plans account for fee disclosure change notices during their transition to a new provider/recordkeeper. As transitions can take a few months to work through Plan details, determine new fees (plan level and individual fees), and finalize how the investments will transfer; it seems having the change notice to participants 30 days prior to their first opportunity to choose investments could be tough. Does anyone have experience with these notices and how you've handled it in the past, specifically when the assets are “mapping” to new investments and the blackout begins about a week prior to the effective date. In this scenario participants wouldn’t have access to their accounts until after the blackout ended.
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