Does a plan need to actually amend the plan document to eliminate the requirement that elective deferrals be put on hold for 6 months?

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Am I reading correctly that one cannot amend a safe harbor mid-year to change in-plan Roth rollover provisions? We want to amend to allow this for all amounts, whether a distributable event or not. Our document currently states there must be a distributable event.

I'm working with an employer who has employees who do not work over the summer. They will continue to be covered under the employer's group health insurance plan but must pay for their portion of the premiums which would otherwise come out of their paycheck. We are concerned about what happens if the employee does not pay their portion of the premiums. My understanding is that there is a 30 day grace period under the ACA and that if the policy is canceled for non-payment, the employee is not eligible to re-enroll until the next open enrollment period. My questions are: [1] Is it correct that there is a 30 day grace period under the ACA? [2] If so, do you know what statute or regulation requires it? [3] Can state laws require a longer grace period (I believe they can for individual plans but can't find any information on group plans)? [4] Is it correct that they cannot re-enroll until the next open enrollment? Any cite for that?

A participant has contributed $20,000 in pre-tax deferrals for the life of the account and a loan was taken in the amount of $7,000. The total cash balance in the participant's account is $15,000. Can the participant apply for a hardship withdrawal for the full account value because technically the basis is $20k? If the full amount is available for hardship withdrawal, is the assumption that the earnings are included in the loan asset account and therefore the withdrawal was correctly limited to solely to the contributions made by the participant?

Suppose you have a typical DB/DC combo but with the DB 21 and 1 and the 401(K)/profit sharing immediate entry across the board. The two plans are a required aggregation group that is top heavy. Do the general rules that prohibit you from restructuring to avoid the gateway apply even if the restructuring is only to carve out the otherwise excludables?

Thinking about plan design. Employer has one owner, 40's, minimizes pay. Would like to start up new plan and willing to increase pay to self to allow for contributions. 401k, safe harbor are fine. But this approach does not mesh well with cross-tested design because ratios are too high to pass. Pay too low for integrated formula to function too. Thinking about other design considerations.

Just wondering how some of the practical aspects will play out with recordkeeping platforms, reporting, etc. For example, the SCP loan default correction. This is great, but suppose a loan defaults in year one. Deemed distribution is reported. Two years later, as allowed under the Rev. Proc., you "correct" this so that there is no taxation. Are you allowed to amend your previously filed income tax returns? How far back can you go to amend a personal return? What documentation is required to do so, etc.?

LLP with 3 PAs (1 for each doctor, LLP covered shared staff) broke up in February 2018. One of the doctors kept the LLP and his PA. Some of the staff left, as did the other two doctors. At this time we assume those two PAs still are in existence (they were on 12/31/18, PYE). All still are participating employers in the plan. When would the plan be considered a multiple employer plan? For 2018, the year the partnership broke up? Or for 2019, the first full plan year in which they were not a controlled group of companies? If the other 2 PAs (doctors) cease to be participating employers, when would that "kick out" the multiple ER "designation?" In the year it happened (like 2019 for example, if the plan is amended) or the year after the amendment? See where I am going with these questions?

If the beneficiary form clearly states the name of the retirement plan and the name of the insurance policy, can the one form be used? A client of ours was trying to cut down on making employees fill out two different beneficiary forms when the employee wants the same beneficiary for both.