"Looking at a plan doc prepared by another. Calendar year plan.

Eligibility for the 401(k) component is 6 months in which at least 1,000 hours of service are required, with the 401(k) component's entry date being the first month following completion of 6 months. Can a 401(k) plan require 1,000 hours of service in a 6-month period, for the 401(k) component?

For the employer's profit-sharing contribution componennt, the participant must have 12 months with 1,000 hours, so that seems fine. (Entry date is dual entry, 1st and 7th months.)"

"I had a sole-prop some time back and had a self-employed 401k plan with Fidelity with EIN of sole-prop. Then I created a S-corp and just used the same plan -- changed EIN to S-corp, changed name to a generic name - MKK-Plan. All good, no issues.

I was thinking of shutting down the sole-prop but never did. Now, one of my clients (for whom I do most of my work) has changed its policy and wants me to handle a task based on my Social Security Number (payment as 1099 contractor). Does not want to use EIN of sole-prop.

I believe I could add the EIN of sole-prop to my current MKK-Plan, but client wants to pay under SSN only.

Can I do the same with my SSN? Fidelity form asks for: "The term 'Employer' includes the following Affiliated Employers covered by the Plan:..." Should I add the following: "MKK - SSN"?"

"Years ago, three participants in this non-ERISA 403(b) plan opened up accounts at Equitable. They all terminated in the early 2000's. After that, the plan started making employer contributions and took more control of the plan (moving all employees to one RK), moving the plan firmly into ERISA 403b territory, which is when we got involved.

So only these accounts were still 'outside', and we've not been reporting them on the 5500 under the 2009 rules. Now the not-for-profit is terminating the plan. We asked Equitable for options, and they told the plan sponsor that they have no authority over those accounts because they are individual tax-sheltered annuities. The plan sponsor spoke to the participants who have agreed in theory to take the money from the plan... but haven't. Does the 2020 IRS guidance apply here? Can they just consider these accounts as not part of the plan any more and say the plan is done?"

"Got a new plan client. The plan document is written with 0% integration level on a 2-tier non-elective. Why would someone do this? What's the logic?"

"The code section in the topic is with regard to a corrective amendment for 401(a)(26). It states that the retroactive amendment must be under the same conditions as 1.401(a)(4)-11(g)(3) thru (g)(5). I am puzzled what if any meaning 1.401(a)(4)-11(g)(3)(v)(A) should be given. It is titled 'Corrective amendment for coverage or amounts testing'. Since the testing at hand is for minimum participation, can this (v)(A) paragraph be ignored? I would think so but I am wondering if anyone else has given this further thought. Generally, a group of employees that satisfies 401(a)(26) may well not also satisfy 410(b) or 401(a)(4). Alternatively, what sense would it make for the additional accruals themselves to satisfy 401(a)(26)? That would seem to be an overkill."

"I have a client that applied to EFTPS, but never received their PIN in the mail. I know generally you can only do a check if under $2,500, but under these circumstances would it be an issue to have the check sent?"