"Boy, the ramifications of this Corona Virus just keep cascading. A Dependent Care FSA only provides reimbursement for approved day care expenses, etc. -- so with most of the day cares shuttered, then participants may wish to reconsider having the deductions from their paychecks if they think they won't be able to use it all, right? I would certainly consider this an allowable situation to change an election. Thoughts?"

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"401(k) plan was moved to a new platform. A part of the agreement for investment advisor fees was to deduct a specified portion from the participant accounts on a quarterly basis. This was properly disclosed to participants in timely notices. Investment company failed to set up this fee deduction for six months. Investment company's position on this: 'Our position is to follow IRS correction principles of returning the plan to the state it would have been in if no error had occurred -- in essence deducting fees from the participant’s accounts." The investment advisors would rather forego the payment than deduct fees from participants. I can't find anything that requires a fix for something like this. Anyone else have a similar situation?"

"The Secretary of the Treasury has the authority to waive the 60-day participant rollover deadline in the event of a federally declared disaster, such as, the coronavirus. Any word of this being part of any kind of relief bill? I'm a TPA. I've been asked whether an individual could receive a 401k or IRA distribution at this time and then roll over to an IRA or qualified plan later even if after the 60-day deadline."

"An employee is sending in some after-tax dollars as a rollover to us and I cannot recall a situation like this. What source would you build in Relius to put these funds into? (I have a call in to Relius also.) Would you put into a rollover source and name it Rollover EE Voluntary? Not sure if I can track basis with that source. Would you build an after-tax source and name it Rollover EE Voluntary? I think that opens up the tracking of the basis, but not sure if this source is picked up in the top heavy calculation. I would think it would be excluded from top heavy calculation. (Of course, it depends on the plan document.) Any thoughts?"

"All assets/annuities of a plan are distributed. Am I correct in saying that we file a Final 5500 on a non-ERISA 'one participant' plan solely because the 5500-EZ instructions tell us to? Am I correct in saying that we DON'T file a Final 5500 on a non-ERISA 403(b) plan solely because the 5500-SF instructions DON'T tell us to? Are there better citations?"

"Is the suspension for 2020 RMD applicable only to DC plans and IRAs? I don't see DB/CB plans mentioned."

"Let's say a sponsor halfway through a plan year wishes to retroactively amend the plan document back to the first day of the plan year to be a Safe Harbor Match plan. Specifically, they wish to amend the plan to change the eligibility requirements for safe harbor contributions and deferrals to go from 1 year/1000 hours to immediate entry. If they make this amendment, will they have to make up contributions for employees who did not defer but may have decided to defer had they had the opportunity to do so plus the safe harbor allocation? EPCRS suggests that, if I inadvertently didn't allow someone to contribute, then I should make an allocation to that individual based on the ADP/ACP group that individual falls in. But I may be over thinking this. Thoughts?"