With the newly released Summary Annual Report model notice updates, were any changes actually made to the wording from the prior version?

I have a sole prop DB plan where the benefit is limited by the 415 comp limit. The Comp limit is still being phase in over the 10 year period. Question: Can the 404 "Cushion Amount" include the increase in the 415 comp limit during the year?

As an ERPA, do you put a Circular 230 blurb at the bottom of your correspondence? Just e-mails? I can't remember ever getting any paper correspondence with that disclaimer on it (nor can I remember I got any paper correspondence from an ERPA).

Using the just-released CPI factor (256.092), I (Tom Poje) have the following:

Year	Catch up	Catch up unrounded	Deferral Limit	Def limit unrounded	Comp Limit	Comp Limit unrounded
2019	$6,000	$6,405.50	$19,000	$19,217	$280,000	$283,740
2020	$6,500	$6,504.00	$19,500	$19,512	$285,000	$288,120

(far column HCE limit unrounded $130,192)

DC $ Limit	DC $ Limit unrounded	DB $ Limit	DB $ Limit unrounded	Key Employee	Key EE unrounded	HCE Limit	HCE Limit unrounded
$56,000	$56,748	$225,000	$226,992	$180,000	$184,431	$125,000	$128,208
$57,000	$57,624	$230,000	$230,496	$185,000	$187,278	$130,000	$130,192

A safe harbor match 401(k) plan currently has a six month eligibility (no hours per month requirement). Due to some part-time students who work on an as-needed basis, the Employer would like to amend the plan to require 200 hours per month as part of the 6 month eligibility. It would like this amendment effective date 1/1/2019. I believe the amendment is permissible, but only PROSPECTIVELY with a 30-day notice. A coworker believes the amendment can be effective retroactively to 01/01/2019 because it will only apply to those hired on/after 01/01/2019.

What if a QDRO is approved but the participant's benefit never gets into pay status? Can the alternate payee still get his or her payments?

Anyone have any experience using EPCRS to correct defaulted loans?

(d) Defaulted loans. A failure to repay a loan in accordance with loan terms that satisfy Section 72(p)(2) may be corrected by (i) a single-sum corrective payment equal to the amount that the affected participant would have paid to the plan if there had been no failure to repay the plan, plus interest accrued on the missed payments.

That's pretty cool, but I'm stuck on the details. I have a 2018 deemed loan with a 1099R. The participant and employer did all they should to self-correct. How does the participant handle the 2018 Form 1099-R? Don't report income and wait for the IRS to ask? Must the custodian issue a corrected 1099? Something else?

I have a small client with a couple of retirees who are interested in the new lump sum window that the IRS has recently started allowing for participants who are already in pay status. One of these retirees was a High 25 and was not allowed to select a lump sum when he retired originally. The client is making steps towards terminating the plan. If it were not terminating, the plan would need to fund up so that they were 110% funded for this High 25 retiree to receive his lump sum. Because it's terminating, does that 110% still apply or does it go away? Logically it doesn't seem to make sense and it seems like they should only fund to pay out the benefits for the plan termination, but logic and the regs don't always agree. Does timing matter? We can't terminate the plan and then create a window to pay out the lump sums. If we create a window for the lump sums, then does the 110% apply since we haven't yet terminated? If we can't do it before or after, how can we do it "at the same time"?