Has anyone tried using the IRS website to request a trust identification number recently? What should be listed for line 7a, and 7b? I would think the "Name of responsible party" would be the Plan Sponsor as the trust grantor, and then the EIN of the Plan Sponsor would be used, but the instructions say to use EIN only if the Name of the responsible party is a government entity. The website will not accept an EIN, and that screen cannot be by passed? Should the instructions for listing a responsible person for the business entity (principal officer, etc) be followed instead? but we aren't applying for an EIN for the business, its for the trust. what have folks been doing?

Assuming the plan document does not preclude the following, can "Excess Allocations" placed into an "unallocated account" pursuant to EPCRS, Rev Proc 2016-51, Section 6.06(2)be used to fund corrective QNECs required under EPCRS, Rev Proc 2016-51, Section Appendix A.05(2)(b, for a missed deferral opportunity? Situation: Sponsor failed to withhold deferrals for an eligible participant, but contributed $7000 to his deferral account anyway. Since the amounts were not deferrals, the amounts are being removed from his deferral account and placed in an unallocated account. This participant now has missed deferrals and is owed a QNEC. Can the amounts removed from his account and placed in an unallocated account be used to fund his corrective QNEC? Please assume there is nothing in the plan document that would preclude such a practice. Thanks in advance for your thoughts.

I should know this, but DB plans are strange. Suppose someone is still working (100% owner) and becomes vested AFTER attaining age 70-1/2. Now must start taking RMD's. Question is: if the RMD method selected is 100% J&S with his spouse as beneficiary, and he dies, since this is an RMD, the spouse should be able to elect a lump sum payment of the death benefit (assuming proper waiver had previously been executed, and plan allows a lump sum), correct? In other words, an RMD method election doesn't lock in that method as a post death payment method for the beneficiary, does it? DC RMD's are so much simpler... P.S. - it seems like 1.401(a)(9)-6, Q&A-14(a)(5) covers this? Or am I all wet? Thoughts on this situation - evidently participant is concerned that if both he and spouse die together while taking the RMD's that nothing further would be paid out to contingent beneficiaries.

DB plan NRA is 62 & 5 YOP. The plan sponsor wants to amend to add an in-service distribution provision upon reaching NRA. My question is: Does the law allow the in-service distribution to be mandatory upon reaching 62 or NRA?