Very unusual situation -- we have a plan that was terminating PYE 06/30/19. They moved money to checking account and paid everyone out. Then without consulting us, instead of closing the account they kept it open and put in an additional $250 to cover bank fees. They now have about $167 remaining. Whereas we had planned to file a final 5500 for PYE 06/30/19 showing the plan terminated, they actually have no participants and a small bank balance remaining. Technically, it seems we would have to have them clear out the account and file a final 5500 for PYE 06/30/20. Any suggestions as to how you would handle this?

[Advert.]

You cannot afford to ignore your collections program. Collecting benefits payments is a complex process -- The Collection Procedures Institute this September will provide you with the information you need to fulfill your responsibilities. Register now!

Plan sponsor (with high employee turnover) eliminated 401(k) plan's fixed matching contribution effective January 15, 2018 and, after payment of expenses, has over $6,000 in the forfeiture account. Document provides that match forfeitures be used to reduce match for the plan year in which they occur and to pay expenses. Sponsor will continue to pay expenses from the account, but it may take a few years. Does anyone think there would be an issue? It's not like the account accumulated over a period of several years. We're following the terms of the plan. Not sure what else we can do.

Self correction by amendment. We meet all other requirements. The only "issue" -- it so happens there are predominantly HCEs. Taxable Fringe Benefits were taken into account when they should not have been. We want to amend retroactively to 2018 as the correction to include TFB. Is that a problem? There's nothing in the new "correction by amendment" that is problematic. It references section 6.02 for correction principles, but it seems I can check off all those boxes too (i.e., it is consistent with general principles).

I have a plan for a collection of medical practices (we'll call it ABC Medicine). There are 7 doctors, they all have equal ownership in the partnership (LLC). The plan document says they are NOT an ASG, and that they are a MEP. There are participation agreements completed for each doctor's practice. The doctors' practices don't have any employees. The employees are all employed under ABC Medicine. Since the beginning, we've tested this plan as if it is an ASG. and only recently did the plan document issue come up. Can you help me understand the difference between an ASG and an MEP? I believe this is an ASG, but I need to be able to explain this to the client. And what kind of VCP corrections will be required if it is an ASG?

I have a 401k plan that wants to remove the automatic enrollment features. Does anyone have a sample notice they can share for announcing this to employees?