One of our locations just closed due to a business decision. Employees were let go. Does this trigger a distributable event for the terminated employees who participated into the plan? Are they eligible to receive 100% of their accounts even if they did not meet the yearly requirement (20% for service after 2 years, increasing to 100% after 6 years)?

We have three members of a controlled group of companies: X,Y, and Z. All three have a standardized prototype profit sharing plan. The adoption agreement states that all employers participate in the plan. Each plan has a different allocation formula -- one is pro rata, the other is fixed, and the third is integrated. Can each employer allocate a discretionary amount to just its employees based on its plan's allocation formula, and then use the general test as applied to all the employees for coverage and nondiscrimination?

Really splitting hairs here, but ... when looking at Appendix A, .05(9) and (10), let's suppose that everyone has been having deferrals withheld correctly, and all of a sudden, for ONE payroll, everyone who is deferring doesn't have anything withheld on a small piece of irregular (but not excluded) compensation. If corrected immediately, does this qualify for the "no QNEC" correction? (Assume no match.) While it seems reasonable, I suppose one could interpret the language in (10) that this isn't a "failure to implement" -- in other words, it seems like that might be designed more for an INITIAL "failure to implement." Has anyone seen/heard of the IRS addressing this issue?

Assume a plan participant (active, or terminated employee) requests information regarding a qualified DC Plan that a company sponsors. [1] Who is required to provide the information, the TPA or the plan sponsor/administrator (i.e., the TPA's client)? [2] Is the TPA prohibited from providing any information because the TPA is not the sponsor/administrator?

I'm older than 50 and have never made a catch-up contribution to my 401k. Can I make one every year from now on? To make the catch-up, can I simply keep contributing to the 401k weekly as I do now until I reach $25,000?

To avoid audit requirement for plan, employer is splitting the plan into two separate plans. Plan provisions will be exactly the same. Since the plans have provisions that are identical, can nondiscrimination testing be performed as if they are a single plan?

While reviewing a plan's 2018 fidelity bond, I see that it is $30,000. Assets reported on the 5500-SF are $305,000 as of 1/1/2018, which includes $250,000 in assets and a $55,000 employer contribution that was not deposited until 2019. I could ask the client to increase coverage retroactively to meet the 10% requirement for 2018, but is this necessary if the assets actually invested in the plan were only $250,000?

Can a 403(b) plan (non-church sponsor) invest in ETFs? It's my understanding that some ETFs are considered mutual funds as long as it is a Registered Investment Company under Section 851(a) of the code. Can anyone confirm, with a cite?