Chippy Posted March 10, 2021 Posted March 10, 2021 Due to a failed coverage test, I need to prepare an 11 (g) amendment. Our firm does not prepare the plan document, can I still prepare the amendment?
C. B. Zeller Posted March 11, 2021 Posted March 11, 2021 Sure, why not? Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance. Corey B. Zeller, MSEA, CPC, QPA, QKA Preferred Pension Planning Corp.corey@pppc.co
Alonzo Church Posted March 11, 2021 Posted March 11, 2021 Make sure that you suggest in writing that the client have the amendment reviewed by counsel. Also, you may want to be sure the amendment does not take your plan out of prototype (if the plan is a prototype.)
BG5150 Posted March 11, 2021 Posted March 11, 2021 16 hours ago, Chippy said: Due to a failed coverage test, I need to prepare an 11 (g) amendment. Our firm does not prepare the plan document, can I still prepare the amendment? Just make sure there is no Fail Safe language elected. If so, you must address coverage per the rubric stated there. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
Nate S Posted August 13, 2021 Posted August 13, 2021 On 3/11/2021 at 9:13 AM, Alonzo Church said: Make sure that you suggest in writing that the client have the amendment reviewed by counsel. Also, you may want to be sure the amendment does not take your plan out of prototype (if the plan is a prototype.) Speaking of prototype and 11(g), what is affect of an 11(g) amendment on a Cycle 3 restatement? We sponsor a FIS Relius(PPD) document for which we were issued a IRS Opinion letter for a document titled as a Non-standardized DC Pre-Approved Plan, which makes it sound like a "prototype" style Plan. Or is a Cycle 3 document in general immune to that issue?
BG5150 Posted August 13, 2021 Posted August 13, 2021 I'd ask Relius that. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
Mike Preston Posted August 13, 2021 Posted August 13, 2021 1 hour ago, BG5150 said: I'd ask Relius that. What would you ask? Sounds like complete gibberish to me.
BG5150 Posted August 13, 2021 Posted August 13, 2021 24 minutes ago, Mike Preston said: What would you ask? Sounds like complete gibberish to me. Maybe something was missed in translation. I'd rather have Relius deal with it than have to deal with it here... QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
RatherBeGolfing Posted August 13, 2021 Posted August 13, 2021 6 hours ago, Nate S said: Speaking of prototype and 11(g), what is affect of an 11(g) amendment on a Cycle 3 restatement? We sponsor a FIS Relius(PPD) document for which we were issued a IRS Opinion letter for a document titled as a Non-standardized DC Pre-Approved Plan, which makes it sound like a "prototype" style Plan. Or is a Cycle 3 document in general immune to that issue? They are called pre-approved plans now rather than prototype or VS Bill Presson 1
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