Plan sponsor currently does not impose any last day employment/minimum hours of service requirement to receive a match. Match is discretionary and is only made at the end of the plan year. Plan sponsor wants to add a last day employment/minimum hours requirement for 2019. Can that be done effective March 1, 2019 if it only applies after March 1? For example, plan sponsor wants to apply current rules for all contributions for January and February, but impose the last day employment/minimum hours requirement for any match made any time after March 1.

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Last year I did a massive review of all of our clients and got the 8955-SSA reporting ship shape, going back as far as we had records to be sure everyone was reported correctly. (These are all DC plans, mostly 401(k)s.) On page 2, Part III, Item (g), I reported the vested account balances of those who had not yet been paid out. I am now reviewing a 2018 report for a colleague who has done an 8955-SSA and has reported the participant's total account balance instead of the vested account balance. The instructions for 2017 and 2018 are not specific -- "For defined contribution plans, enter the value (in whole dollars) of the participant's account." It doesn't seem to address the fact that their total account balance and their vested account balance often are not the same thing. How do you complete that item?

We have a client with a 401(k)/profit sharing plan with prevailing wage contributions. We just discovered that in 2018, they increased the rate of prevailing wage contributions, causing a large nondeductible contribution amount. We can reduce it a bit by pushing a post-year-end deposit into the 2019 fiscal year deduction. Another option to further reduce the nondeductible amount may be to retroactively amend the plan to bring in an excluded class, and employees who had not met initial eligibility, and give them a profit sharing allocation (the plan is not Top Heavy). I know this would require approval under VCP to be sure it's acceptable. If the client were to do that (assuming waiving the VCP submission), what would likely be considered a "meaningful benefit"? Would 1% of compensation work, or should be more conservative and give them 3% (to match what the IRS considers the minimum for Top Heavy)? They will still have a nondeductible amounts, with a 10% penalty and offset to the 2019 404 limit.

To date I have successfully passed the ASPPA RFP and DC-1 working toward the QKA designation. However, I am hung up on the DC-2 test. The odd part is I pass the practice test but not so successful on the actual test. I have been through the materials and taken many practice test. Not sure how to proceed at this point. Suggestions?

Safe harbor 401(k) plan for medical practice has 3% SH NEC only to NHCEs. During 2018, physicians over age 50 deferred $24,000 rather than $24,500 due to clerical error by payroll person. Can they designate $6,000 as catch-up, leaving $18,000 to count toward their maximum annual addition of $55,000? Or do they have to count the first $18,500 as regular deferrals before counting any as catch-up? Trying to make room for increased profit sharing.