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Posted

some lively discussion on the Q and As in regards to 'otherwise excludables'. we still have no clear guidance on this one, but there was sort of a promise that something would get done in this area. in the past the informal guidance was that you could use maximum exclusion and not worry about the plan's entry dates.

this time there was insistence from the IRS that the plan's entry dates had to be considered. probably the more important issue was whether one could be penalized retroactively for following a procedure that was imformally given an ok. I'm sure we will see more on this one.

........

had a chance to actually meet and talk (if only for a few minutes) Sal 'Mr. ERISA Outline Book' personally.

from time to time I have tripped across a few typos in his book. because of the nature of these typos, the e-mails have been rather interesting - one involved the knights of Ne (or however that is spelled) from Monty Python, and another I had signed the correction from Jethro Bodine and he responded with a thanks from Jed Clampett.

......

It was especially meaningful to me to sit and talk to someone who found one of the custom Relius reports I posted on Benefits Link as being very useful- maybe not in the format I had, but as something they could easily modify for their purposes. one never knows if it is worth the hassle of posting such things.

......

the talk went well, but I almost gagged for a portion of it due to a tickle in the throat. ugh. as for the 'pension' song, well, of course on has to remember humor is individuallistic. it seemed to go well. always great to hear some chuckles during parts of the song.

Cats in the Cradle not by Harry Chapin.

The plan arrived just the other day

The company added a 401(k)

They put in a match, and what can I say

I deferred in the usual way

The cash was growin’ ‘fore I knew it, as I put away

I’d say, “I’ll have a lot some day, yeah

You know I’ll have a lot some day.”

refrain:

And the cat’s in the cradle and the silver spoon,

Little boy blue and the man in the moon.

“When will I retire?, well I don’t know when,

But I’ll have a good time then

You know I’ll have a good time then.

The plan turned 10, just the other day

I said “Thanks for it all, I’m doing okay”

I invested low, now its high today

I’m glad I deferred 10% of pay

As I saved away, my wife her smile never dimmed

Said she “I admire him, yeah,

You know I admire him.”

Refrain

The plan was tested just the other day

It failed ADP in a big time way

They put in a QNEC once in a while

Good news for me I said with a smile

The deferrals were too high for the HCEs

See you later, can I thank them please?

Refrain

I retired just the other day

I was sick of work and the rate of pay

But I said “The 401(k) was such a good find

The money is there and it grew over time”

Well the job it was a hassle, but now I’m free

I recommend you save like me

Recommend you save like me.

Refrain

Posted

Tom, I wish I'd seen the performance. However, with the Christmas season approaching, the best I can do is offer the following composition, which you have my permission to perform at your office party if you are so inclined. To the tune of "The First Noel."

In the rooms, at DOL

The director did say

To certain poor TPA's slaving away

In cubicles where they

Work without any sleep

On the cold Winter evenings with papers piled deep.

DOL, DOL, DOL, DOL

DC disclosures are tricky as He%%.

We looked them up

And heard cries from afar

From TPA's asking "Will this change the SAR?"

And to them all

PPA brought the light

And gave employees

Promise that they'll win the fight.

DOL, DOL, DOL, DOL

DC disclosures are tricky as He%%

And the JCT

Gave writeups for thee

Using gibberish that's contradictory.

DOL, DOL, DOL, DOL

DC disclosures are tricky as He%%

Participant directed investments are free

Or they should be, by golly, in 404©

And the statements required, we'll quarterly make

Using most recent data not easy to fake.

DOL, DOL, DOL, DOL

DC disclosures are tricky as He%%

Posted

now that is real cute. too bad ASPPA doesn't run something during the season. that would be cool.

ugh. don't get me started on Christmas. last year I showed up dressed as the Grinch. that sure was a shock to people.

every year I go through a panic, what if they ask me to talk again, cuz then I feel 'obligated' to 'discover' a lost pension song. that ain't easy. Oddly enough, once I decided that Cats in a Cradle had possible potential the verses sort of just matched the actual song and that was real easy.

Posted

I have a question for you, Tom, since you are on the Q&A committee. Why on the Q&A handout were most of the questions not answered?

Posted

I think there are a couple of things that could explain.

one is that the db questions were tossed into their own session. this means the handout for the big session did not include any of those questions and answers that would have been included in the past. This is something new that is being tried, I think there are a few bugs to iron out in this area - e.g. how much time should the session in front of everyone.

secondly, I included everything that came in.

last year there actually was a 'second set' of questions that weren't answered either. some people got those, some didn't so the amount of unanswered questions was probably about the same.

lastly, the meeting with the IRS officials the month before was cut a little short due to some unforseen meetings that came up that day. believe me, seeing how the whole process works gives me even more admiration for the IRS officials involved.

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