"I am unclear about the cutoff date for needing to do the Cycle 3 for DC plans. Have numerous plans that were terminated by resolution/amendment but slow in distributing out all the assets. If there are assets remaining as of 7-22-2020 does the plan need to be restated? I have some situations where the client didn't want to file for the closing letter. On the DB side, I believe the cycle won't start for another 2 years and lingering assets now won't be a problem. Also, my sponsor is FIS -- I wonder if I am getting a bad deal of $250/month? What are others using?"

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"My client has a fiscal ending 9/30 but their 401k plan year is calendar. We started a cash balance plan for them and wrote the plan document to use fiscal year comp, thinking that this is what they do for their 401k so it would simplify things to use one census. Also, because the two plans are combined plan tested. In February after the second plan year, we discovered that they're actually giving us calendar year comp and that the 401k plan document bases contributions on calendar year. Can I now amend the CB plan retroactively to use calendar year as well? Or is it too late to do that, being after the plan year end? (The differences in comp would only affect NHCEs since the HCEs all earn over the 401a17 limits.)"