Client is a religious organization with both 401(a) and 403(b) plans. Participant terminated employment and requested distribution. It was delayed because of an incorrect address. During the delay period (i.e., after the distribution would have otherwise been made but before it actually was), the plan administrator received a consent order for a pending divorce. Neither the sponsor nor the administrator (which is a MAJOR provider) seems to have any written QDRO procedures for the plans.... it's just been a practice where the administrator generally receives a DRO and the plan administrator approves it. Are the plans in compliance with Code section 414(p)(6)(B)? Should the distribution still be made? Given the financial situation laid out in the consent order, there's a chance that the spouse would get the full benefit available under one or both of the plans.

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Company A has a 401(k) Plan. On March 1, 2018 they were purchased by Company B (no prior relationship) -- a stock purchase. Company A terminated its 401(k) Plan as of February 27, 2018. All assets were distributed by June 2018. In regards to who signs the 5500 for 2017 and the final return for 2018, isn't Company A responsible for the 2017 filing? Because this was a stock acquisition, and the payouts and final 5500 are processed after the stock acquisition, is Company B responsible for the filing? Or does this responsibility still fall to Company A?

Premium-Only Cafeteria Plan's provisions allow salaried employees to qualify after 1 month of service. Hourlies after 3 months of service. Because the eligibility to participate for "that plan year" has everyone being eligible, does that mean it passes the reasonable classification? Or am I misunderstanding, and each "sub-class" must pass the safe harbor or the unsafe harbor test? They wouldn't necessarily ALL be eligible for the Plan Year if they were hired quite late in the plan year, so I suppose you would have to do the safe/unsafe harbor testing, which normally would pass with flying colors anyway.