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I have two separate situations with a safe harbor plans: one that is trying to join the MEP and one that abruptly left and went to a large national payroll company. The first plan is a safe harbor plan that is being administered by a national payroll/benefits company. They were informed that the plan was leaving and stopped accepting payroll contributions in November. I am trying to contact the payroll company conversion specialists and ask if this is a fact. Because this is a safe harbor plan I thought we should merge the plans effective 1/1/2018 but the advisor wanted to start the plan 12/1/2017 because of this situation. Should we make a quick amendment to allow contributions to trustee directed (i.e. pooled) and set up a checking account in the name of the plan so we have somewhere to hold the assets? The other safe harbor left the MEP abruptly in November 2017. I have contacted the client and asked if the payroll company he went to had provided any consulting about the impact on the safe harbor but have had not response. Any advice would be appreciated.
