My employer (a TPA) is telling me the QDIA notice requirements fall on the fund companies we work with (examples: Transamerica, Nationwide, Voya, Hancock) and the plan’s financial advisor. We as TPA do nothing with the QDIA notice. This doesn’t seem right to me. I had a financial advisor tell me he expects the TPA to take care of it. How do other TPA firms handle the QDIA notice requirements?

Plan defines comp as W-2 comp, but does not include post-severance pay for deferrals, match or non-elective contributions. Terminated participant received severance pay but we don't know yet exactly what constituted the severance pay. I would assume at least part of the final check was unpaid vacation, sick leave, etc., and possibly the customary 2 weeks of "severance pay." Do we include all or part of the severance pay in calculation of SH NEC or not?

I am trying to figure out if the S corp HSA contribution for a more than 2% owner is subject to UI/SDI in California on quarterly forms. I am aware that the S-corp HSA contribution needs to be entered on W-2 in Box 14 and that Box 1 and Box 16 (State) needs to have the HSA amount of $6,900 included. I have contacted a CPA and was told that health insurance and HSA are only subject to FIT/SIT, not UI/SDI. Is this correct for California? The payroll provider did not include the HSA to be taxed for UI/SDI -- only PIT wages on California Quarterly DE9c. Is this correct? The Edd information sheets states employer contribution to HSA is subject to UI/SDI. Is the info sheet referring to non-2% employees who have the contribution reported in Box 12W instead of Box 14 for 2% shareholders? I would like to know that payroll is correctly paying my taxes.

Non-profit started a new 401(k) plan for contributions moving forward. The legacy 403(b) is being left as is with no new contributions, but there remains a large forfeiture account, which exceeds payable fees. Can such forfeiture account be transferred directly to the new 401(k) account to be used for employer contributions over there?

Will someone please provide me with an IRS direct email address or address? This is regarding a tax-qualified plan, under section 401(a) that is subject to 401(a)(13)(B) and to 414(p). Seems like a simple question, but I just cannot find the appropriate address nor email address.

I'm taking over a plan that has immediate force-outs in the document for vested accrued benefits of less than $5,000. I suspect the provision was not followed by the prior TPA, based on how the assets are set up (individual brokerage accounts) and the fact that we won't be monitoring the plan on a daily basis. So it doesn't seem like the right fit for this plan. Is it a prohibited cutback to change this to happening after the end of the year of termination in the document?

I’m considering selling my TPA practice. I’d like to hear feedback on the process from anyone who has gone through this experience.

In a divorce situation, both parties established 401(k) with new employers after the date of separation (in CA). These 401(k)s are separate properties belonging to each party but were opened with marital status as 'Married'. Is a QDRO needed to update marital status and beneficiary post-divorce? QRDO is needed to divide community property 401(k). But in a situation where both parties decide to retain their respective 401(k) and forever waive rights to this community property (similar amounts), is a QDRO needed to update marital status and beneficiary post-divorce -- i.e., is a QDRO needed to waive these rights? Finally, is it correct to assume that QDRO doesn't apply to IRA rollover and Roth IRA accounts?

In general, I am pessimistic about the 3(16) business model, but I get that there are aspects of it that appeal to clients. My question is, do I have the latitude to pick and choose which things I will offer as a 3(16)? So for example, I think it rather unappealing to clients to take over the deposit process because most clients want to be involved in ACHing funds out of their own operating account. But I think in general clients LOVE the idea of a TPA signing off on distributions. Signing a form 5500 is not a big deal since I already prepare a signature ready form. But responsibility for sending out notices? Quite appealing. So the question is, can I have a "3(16)-lite" offering, charge a little bit more for it, and take over those things that are the most value added (emphasis on the word value). I already understand the concept behind the full suite of services, so no need to sell me on that!

In a plan where everyone is in self-directed brokerage accounts, two of the doctors (of course) have stumbled onto a non-publicly-traded stock that they want to buy. The financial advisor can't get them access to it through his platform, and the doctors aren't old enough for in-service distributions of any sizable amounts, so they are looking to change brokers to get access to this asset in the plan. The asset itself has a minimum. I've heard varying accounts of either $25K or $10K to buy in. Is that in and of itself discriminatory? If it's $25K, then no one else besides the doctors have that much in their accounts (at least as of 12/31/18). But what if it's $10K? Pretty much everyone has that much.