When the document states compensation is only counted while a participant and entry is 01/01 & 07/01, can compensation be estimated by dividing full year compensation in half, or should I go to the client and ask for 07/01 -- 12/31 actual compensation? I have a payroll report for the full year but not quarterly and client isn't great at responding.

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Running the ADP test for a traditional 401(k) plan based on compensation net of salary deferrals. A participant has compensation of $300,000 so she is being limited to $275,000. When we reduce her compensation for $18,500 of salary deferrals, is it subtracted from $300,000 or the $275,000 of limited compensation?

Any word yet on proposed changes to hardship withdrawals? Is anything final?

If matching contributions may occur per payroll period, with the amounts populating each payroll period, if the vesting schedule is modified during the respective plan year, must one correlate the vesting schedule extant at the respective period when the matching contribution occurred, and then apply that vesting when the participant severs from employment? May only safe harbor matching contributions occur per payroll period?

I am representing a client who is being offered a job with a new company, except that the company does not offer a 401(k) plan. She is likely to accept the offer but thinking of funding a traditional IRA as an option to replace the 401(k) her new employer will not provide. She also has a side business which she hopes to continue to maintain and is considering a solo(k) to help her fund her retirement through that business. Would the maintenance of the solo(k) result in her being treated as an active participant in a retirement plan for IRA deduction purposes? Because active participation is reported on the W-2 issued to an employee, I'm thinking the answer is no.

Plan is self-insured. I've been told a plan administrator can override a denial and authorize payment be made for claim previously rejected. Is that accurate?

We have a 401(k)(12) safe harbor 401k plan with the basic match that we want to restate to become a QACA safe harbor match 401(k) plan under 401(k)(13). Can the QACA match have a 2 year vesting schedule not just for new hires but also for existing participants with a traditional safe harbor match account that is 100% vested? Our document sources these accounts separately -- it has a separate definition of QACA match in the document.

Current plan document allows for in-service distribution for participants who are over 59.5 and employed for 5 years. The withdrawal is restricted to once a year. The client wants to amend the plan to allow multiple (periodic) payments of in-service distribution for participants who are over 70.5 and leave the restriction for once a year for participant who is 59.5. is this allowed?

Participant elected in 2015 to contribute Roth 401(k). From 2014 through June 2018, the participant contributions were inadvertently set up as pre-tax in all respects (W-2 reporting, deposits at recordkeeper, withholding calcs, etc). What to do? Note: The participant has since rolled his entire balance out to an IRA, but if it helps we can start by assuming the money is still in the plan.