I have started working on a 403b plan that has a compensation exclusion of "coach's compensation". Provision does not specify that it applies only to employer contributions. Some people are only coaches so they have plan compensation of $0, effectively excluding them from the salary deferral part of the plan (it seems to me). Does this situation create a problem with the universal availability requirement for the 403b benefit?

Does anyone have a condensed version of the Summary of Accounts Detail that shows shares and sources, that may be a little prettier than what Relius has, that you'd be willing to share?

The current prime rate appears to be 5.25% (WSJ). What are plans using currently as the interest rate for plan loans?

A governmental employer impermissibly adopted a 401(k) plan, in spite of not being eligible for the grandfather rule. It appears that this situation is not one contemplated by EPCRS, inasmuch as the plan as a whole is qualified, but the purported elective deferrals would not be a cash or deferred arrangement (and thus would be after-tax). The client would like to follow the procedure for an employer that adopts a 403(b) plan, even though it is not eligible to do so -- i.e., stop all contributions to the plan, pay the VCP fee, and make distributions only when otherwise permitted to do so. Has anyone gone to the IRS to negotiate a VCP-like solution to such an issue--one that would protect the pretax status of the employees' contributions? What was the outcome?

Assume a Solo 401(k) is the only one-participant plan maintained by the sponsor. If the total assets in the 401(k) exceed $250,000 around halfway through the calendar plan year but then drop below $250,000 by the end of the year, does a 5500-EZ have to be filed?

At the end of the plan year, a sponsor must file a Form 5500-EZ for each of their one-participant plans when the total combined assets of all one-participant plans the sponsor maintains are greater than $250,000. For purposes of calculating the total combined assets, is a SEP IRA included in the calculation?

I have a current small client (approx. 15 employees), with a 401(k) plan with elective deferrals -- it's a 3% Safe Harbor Non-elective Maybe. The client is deciding whether to amend it to be Safe Harbor for the 2018 plan year so that we can send the required 30 day notices ASAP. The plan currently applies the SHNEC to ALL participants, but the client is considering excluding all HCEs from the allocation in the future (4 employees in addition to himself). Could he make that change as part of the 2018 SH amendment and notify participants that HCEs will not receive a SHNEC for 2018? Or must he wait and amend the plan for 2019 to exclude HCEs from the SHNEC?

At the end of the plan year, a sponsor must file a Form 5500-EZ for their plan when the assets of the plan are greater than $250,000. For calculation purposes, I'd like to know what's included in assets. At the end of the plan year, an Individual 401(k) has a balance of $240,000 and an outstanding loan of $30,000. For purposes of Form 5500-EZ, are the total assets $240,000 or $270,000?

Someone is insisting that a 401(k) plan must have a calendar Plan Year. I don't see any such rule. Is there one?