"Have any relief measures been put into place for Safe Harbor Match Plans that are also Top Heavy? Company is looking for ways to manage their costs during this time."

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"Even in years with no disaster or public-health emergency, many administrators of employee-benefit plans -- whether acting directly, or by some agent -- routinely extend a Form 5500 due date from July 31 to October 15. If the DOL doesn't grant an extension due to the coronavirus, is there a practical consequence beyond the make-work of completing and sending an extension form?"

"Have an employer who terminated 35% of participants. If this coronavirus situation improves by November, they may hire half of the terminees back. Apparently there is no special coronavirus exception to the partial plan termination rules. This is a plan year determination so we really do not need to determine whether a partial plan termination has occurred until after 12/31/2020 in this case. The employees where all laid off on March 28. Since these days most former employees want their distributions immediately, how are others handling this? My thought is if someone is 40% vested, they get paid their vested benefit now and if it is later determined that a partial plan termination has taken place, they subsequently get paid their remaining 60%. Does this seem reasonable? What if it is later determined a partial plan termination has occurred and their remaining 60% was worth $20,000 when they received their distribution, but it turned into $10,000 by the time they received their subsequent distribution due to plan investment losses?"

"I saw the great discussion on the PPP earlier in the week, pertaining mainly to prefunding 2020 contributions. Are 2019 contributions eligible for consideration in the PPP? For example, employer was planning to fund a 2019 profit sharing contribution by their 2019 extended tax filing deadline, and makes the deposit during the 8-week window."

"Company A recently purchased all the stock of Company B. Company B was a subsidiary of a big conglomerate and participated in their 401k, which included Roth contributions. Company A's plan does not allow Roth, and they'd like to keep it that way. They don't even want the Roth rollovers coming into their plan. Company B employees were not given distribution options. They were told that all funds would be transferred to Company A's 401k (before Company A had considered the Roth issue). They would prfer to bring over all assets EXCEPT Roth. Is that allowed? Can the merger instrument state that only non-Roth assets will be merged, such that the Roth assets would need to remain where they are?"

"Pre-SECURE Act rule inquiry (based on a fictitious couple): participant dies at age 90 (after starting RMDs). Surviving spouse is the sole designated beneficiary, who dies at age 99. ULT factor in year of death for participant is 11.4. SLT factor in year after death for surviving spouse is 2.9. So factor in year after death is max (11.4 - 1, 2.9) or 10.4, which is then subtracted by 1 each year thereafter?"

"Most IRS offices are closed. I have a few DB plans for which we will need to file a Form 5307 application. The IRS website says they 'continue to process determinations for employees plans,' but it's not entirely clear what that means. (https://www.irs.gov/newsroom/irs-operations-during-covid-19-mission-critical-functions-continue) Obviously, I will push the application submission dates off as far as possible, but does anyone know if U.S. Mail and/or FedEx/UPS packages are currently being delivered/accepted?"

"Our company announced our plan was being amended for CARES over the next few weeks and participants can expect the changes to be adopted. Just curious if anyone knows what balances are typically available with these things as standard (I realize there not one necessarily). Vested/invested, employee/r contributions, etc. -- I never knew there were so many categories for a 401k balance. I'm fully vested and mostly wondering what categories might be unavailable when the plan is rolled out. For example, the available for a 'hardship withdrawal' currently is only $44k but vested balance is significantly higher than that."