ERISA Section 411 makes it at least improper for someone convicted of any of a long list of crimes (if the conviction or the end of the imprisonment, whichever is later, is in the past 13 years) from serving in any almost any role regarding an employee-benefit plan. Does an insurance company, before issuing an ERISA Section 412 fidelity-bond insurance contract, do anything to check whether a person whose dishonest act the contract would insure lacks a disqualifying conviction? My intuition tells me that the size and probability of an insurer's potential liability on a typical fidelity bond is so small that an insurer doesn't bother checking anything. But I'd like to be wrong about that.

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Client wants to set up 3 pools of money: Conservative, Moderate and Aggressive. The underlying securities will be stocks and bonds. Has anyone figured out how to handle fee disclosures on this? Note that we will be doing quarterly valuations, and participants can choose to switch quarterly. And it's a small group, almost exclusively investment experts. They're not really worried about would happen if the market tanked kind of a thing. Maybe they should be, but they know their employees well. What I'm really interested in is the fee disclosure requirement.

Company started in July 2018. For a calendar year plan, we will have a 01/01/2018 effective date. Do we have to pro-rate the TWB if using imputed disparity to pass the general test?

Plan sponsor had late deposits of elective deferrals for multiple pay periods in 2017. Due date for Form 5500-SF and Form 5330 were extended by filing Form 5558; $19 was paid with extension for amount due on Form 5330. After preparing Form 5330, excise tax total is $19.21. Is it necessary to remit $0.21 with the form? Is there some kind of de minimis that would apply to this situation? Thanks.

I've been tying myself in knots on the math trying to compare the cost-sharing implications of switching from a Cadillac health plan to a higher deductible plan with an integrated HRA. The former is a family plan with a standard deductible of $0, no coinsurance, and a max out-of-pocket of $3k/$6k (per person/per family). The latter has a standard deductible of $3k/$9k, no coinsurance, and a max out-of-pocket of $5k/$10k. Copays are naturally a bit higher, and the plan is obviously more restrictive all around. If one of the goals is to minimize cost-shifting to employees, how would you go about determining the appropriate HRA contribution amount? My current thinking is that this should be based simply on the increase in the max out-of-pocket i.e., $4k ($10k -- $6k). But I'm being thrown off by the much larger increase in exposure from the high deductible ($9k vs. $0). I understand that comparisons will vary depending on total medical expenses, the number of visits, procedures, etc., and should account for the employee's savings from lower premiums. So it's complex. Can someone help to clarify my thinking and perhaps add some insight on how best to approach this?

Code C Purpose: "Use this code for a participant previously reported under the plan of a different plan sponsor and who will now be receiving a future benefit from the plan reported on this form. Also complete columns (b), (c), (h), and (i)." So a client is merging Plan A into Plan B. Plan A happened to be an employee contribution only and Plan B happened to be Employer contributions only. Both are sponsored by the same plan sponsor. Based on the instructions above, I am planning on NOT reporting these folks as a Code C on the surviving plan. Do you agree?

Basic Admin 101 question. Plan compensation is based the participant's date of entering the plan. For the purposes of allocating a profit sharing contribution, does one use compensation during the entire plan year, or only compensation received after the participant entered the plan?