I have always used the UP-84 mortality table when doing cross testing on a New Comp Plan. My plan is failing the average benefits test slightly (69.89%). The administration system I use includes a table called 2017 417(e)(3). If I use that table, the Average Benefits test passes (70.20%). The plan document doesn't say which table to use. OK to use the 2017 417(e)(3) table?

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We have a partial plan termination of a pooled profit sharing plan where 69 our of 76 participants have balances under $5,000. 13 of them have less than $200. Our office uses a popular distribution company that charges $35 per person to prepare a distribution. They do the 1099-R at the end of the year. We also charge a fee on a sliding scale for processing distributions, although for balances under $200, we usually do not charge. In this case, we may need to charge something if we have to invest a lot of time in hunting missing people. That issue aside, for 8 of the 13 people, there isn't even enough money to pay the processor's $35 fee. My question is this: are these little balances considered "de minimis" amounts and can they simply be forfeited? Or must the employer pay the $35 per person so the distribution company can cut a check for as little as $4.26 up to $179.02?

I know that in-service withdrawals are a protected benefit, but what about limitations on such withdrawals? For example, a participant is allowed only 2 withdrawals per Plan Year. Would this also be considered a protected benefit? Or would this be an administrative election?