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Can a 2019 Contribution be made to a SEP that has not yet been esablished? We intend to set up a plan for an employee before July 15, 2020 and make a contribution. Can we postpone to OCT 2020 if we elect an extension? Comments? Thnak you! Ken Phillips

I have a plan that has quarterly entry for participation. (no age requirement) The plan excludes Part -time, Temporary, and Seasonal employees. In the Corbel document, 1,000 hours of service was used to describe the PT, temp, and seasonal employee. Here is my dilemma, because the plan has only the Qtrly entry requirement, the Subsequent eligibility Computation Period was not completed. Plan year and Anniversary year are the common choices. If an excluded employee would happen to not work the 1000 hours for the next year, that's fine, they would not become eligible. But what subsequent eligibility comp period do I track next? I cannot find anything in the master plan to default to plan year or anniversary year. The plan needs to choose plan year or anniversary. Am I missing another provision in the document that might clear this up?

Good evening, I could use some help in determining the entry date for an employee who, on two occasions, worked a short period before terminating, and was ultimately hired full-time after his second termination. He never met the service requirement prior to being terminated on either occasion, but currently has satisfied it. The potential issue is, the plan sponsor allowed the employee to participate on the entry date following his satisfaction of the service requirements following his most recent hire date, but I am of the opinion that he should not have been allowed to enter the plan until the beginning of the most recent plan year. Plan specs are as follows: Plan Year is 11/1 - 10/31 Plan eligibility is 1 YOS/Age 21 with monthly entry dates Actual hours counted (1000) No BIS rules apply ECP shifts to plan year after initial ECP ends Paraphrasing & summarizing plan's master document provision regarding rehired Eligible Employee who failed to satisfy eligibility requirements: for purposes of applying any shift in ECP, employee's prior service is taken into account and employee is NOT treated as a new hire (emphasis mine). Employee data is as follows: Birth date: 6/27/90 Initial Hire date: 6/28/10 Initial Termination date: 8/25/10 1st Rehire date: 5/11/13 2nd Termination date: 8/16/13 2nd Rehire date: 5/12/14 Plan sponsor allowed EE to begin participation after 6/1/15 Hours worked during ECPs (using my understanding of plan document): 6/28/10 - 6/27/11 - 246 11/1/10 - 10/31/11 - 0 11/1/11 - 10/31/12 - 0 11/1/12 - 10/31/13 - 527 11/1/13 - 10/31/14 - 960 11/1/14 - 10/31/15 - 2080 The plan sponsor, I believe, began a new ECP as of 5/12/14, and has credited the employee with a year of service as of 5/11/15, allowing him to participate as of 6/1/15. I believe that, since there are no BIS rules in effect, and the plan document does not seem to allow for "resetting" the ECP to his latest rehire date, that he should not receive credit for a YOS until 10/31/15 and he should not be allowed to participate until 11/1/15. (Our recordkeeping software agrees with me, not that that means anything.) I actually hope I am wrong on this one because the employee has been making deferrals since June 2015 and received an employer contribution for 10/31/15, so corrections would be in order if I am right. Thanks to anyone who read this far...