austin3515 Posted August 13, 2015 Posted August 13, 2015 Small non-profit has all its money at Vanguard. Previously took the position that it was non-ERISA b/c deferral only. But because the additional cost is minimal and because there are limited investment options, we are suggesting just to do the 5500's and treat as an ERISA plan. I think this is consistent with the DOL's analysis which takes into account the participants ability to choose from multiple vendors. So let's say we decide to change the status. Effective date of plan is 1/1/2000, and 2015 is the first year we will file (forget about 2014 and the extension, it would just be a distraction). We check the first report box. Then what happens? Anyone done this? It seems like the DOL should be sympathetic here... Austin Powers, CPA, QPA, ERPA
mbozek Posted August 18, 2015 Posted August 18, 2015 Why not just create a new plan effective in 2015 and merge the old plan assets into the new plan. Or file 5500s for all the years since 2000. I think the penalty is minimal -$750. mjb
austin3515 Posted August 18, 2015 Author Posted August 18, 2015 That's a brilliant idea! Austin Powers, CPA, QPA, ERPA
jpod Posted August 18, 2015 Posted August 18, 2015 Is there any reality associated with the concept of merging one 403(b) plan into another?
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