"A plan participant wants to purchase life insurance owned by his qualified 401(k) plan. The plan and the participant intend to follow the requirements of PTCE 92-6 and eliminate the PT concerns. However, the participant wants to use IBM stock to purchase the insurance. I could argue that as long as all the requirements of 92-6 are met an in-kind purchase of the insurance should be covered by PTCE 92-6. However, there is also a concern that the use of IBM stock to purchase the insurance will be deemed a separate prohibited sale or exchange between the plan and the participant party in interest and will not be covered by 92-6. Any thoughts on this?"

"If someone changes employers mid-year, do the employer contributions made to his DC plan with his first employer get aggregated with the employer contributions made by his new employer's DC plan when considering the 415c limit OR is the 415c limit separate for each employer?"

"The PBGC has been sending non-filing notices for plans that were due 10/15/2021, even though these plans are entitled to the January 2022 Ida extension. Clients are getting upset. Any thoughts, insights, or advice would be much appreciated."

"A management service organization with multiple entities under them adopts a safe harbor 401(k). Are all adopting employers of the plan required to make the 3% SHNEC every year, or do the individual employers have a choice?"