"Can the assets of multiple unrelated 401k plans be commingled into one single trust in order to benefit from cheaper costs through economies of scale? I know the DOL has stated that there is nothing in ERISA to prevent this for multiple plans sponsored by employers under common control but it's unclear whether that would apply to unrelated employers as well."

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"I know of the 30-days rule for providing notices. But what if someone decides in December to start a SH 401(k) plan? Can they not do it? What if it's the first week or two of the month? Wouldn't that be like an "as soon as administratively feasible" situation?"

"We have a defined benefit plan, covering only a Key employee, and then in 2016, 3 other employees joined the plan and accrued at least a 0.5% accrual. The plan was frozen 12/31/2016. No other employees. The question I am dealing with whether I am satisfying 401(a)(26) for this frozen plan since 2016 as there are no accruals as the plan is a hard freeze. Since there are 6 "participants", am I satisfying 401(a)(26) since 2016? I find the reg hard to follow for db plan subject to a hard freeze."

"The client had a DB plan for many years, which became very overfunded. A new DB plan was created, with the idea of a carve-out or offset between the plans. Plan A covers 2 participants and provides a benefit of 6% x service accrual. Plan B provides a benefit of 8% x participation. In Years 1 and 2, the benefit accrued in Plan A is fully offset by the Plan B accrual. Question is, how to satisfy 401(a)(26) for Plan A for these years? From what I have studied, 401(a)(26) might not be satisfied until both plans can be aggregated for 401(a)(26)."

"The model Rabbi Trust from the IRS seems to limit trustees to the following: 'a bank trust department or other party that may be granted corporate trustee powers under state law.' Does this preclude an individual from service as trustee of a Rabbi Trust? I would not think so, but I note they use the terms 'granted CORPORATE trustee powers...' Also, do you agree that an individual cannot serve as the trustee of his own account because to so he would have constructive receipt of the funds?"