If an employee works less than 1000 hours for the past 5 years and in 2019 they work over 1000 hours, when would they enter the plan? 1/1 or 7/1 - 1 year - Age 21 - Actual hours. Thanks.

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Another question on this. The corrective amendments to conform plan language to actual operation - I'm guessing that this will not override the normal timing requirements for advance notice in a safe harbor plan? Or, is it meant to allow self-correction n such a situation?

Short version: we took over a pooled profit sharing plan a few years back... all pooled except for a few participants with life insurance. No one new has purchased policies (we've made the plan sponsor give each participant a form to sign off saying that they don't want to purchase a policy), and all those with policies have terminated and gotten paid out except the owner, so his is the only policy left. Can the plan be amended to no longer allow life insurance going forward without causing a nondiscrimination issue? Or are they doomed to be stuck in CYA-mode until the owner gives up his policy? Thanks.

This is a cash balance plan for a sole proprietor with employees. We completed the annual contribution calculation, client asking if contributions must be made in cash or he can transfer some personally owned securities into the plan as contribution. I'm leaning towards "no"; the doc makes no mention.

Hello! Long time lurker, first time poster. I'm still relatively new to the game but I've completed the requirements for my QKA and I know enough to know there's still a lot I don't know yet. We've taken over a plan and the plan contact informed a member of our admin team that their prior TPA had warned them of a penalty for the plan failing ADP testing for three consecutive years. I've not come across this in any of my studies so far, and I cannot find anything about it anywhere - not on ERISApedia, not on tag, google, IRS site, nothing. Now, I know that the layperson generally has no idea what we're talking about when we discuss ADP/ACP testing or coverage or anything else, so the likelihood of the client having misunderstood something that the prior TPA said is certainly present. But have any of you ever come across this? If so, could you point me in the right direction? Thanks!

Hello all, Had a client that didn't start an employee's deferral on time back in 2018. Since the missed contributions cross two plan years, how are the QNEC, missed match, and earnings tracked in testing with the 2018 testing being completed already. The entire correction is being made in 2019. Also just wanted to clarify that the missed match goes in as match source and not a QMAC since it's corrective. Thanks!