"Plan subject to J&S did not sign forms with J&S options, what is fix?"

"Quick question - Plan has its own table to convert the normal form of "10 years certain + life" to other forms, including single life annuity. For 417 purposes, do I do the lump sum first by: a) Convert 10cc to life via the plan factors, and then convert the life amount to lump at 417 rates, or b) Convert 10cc to lump with 417e factors, but convert 10cc to life separately with plan factors (even though the lump sum value of that life annuity would be different?) Thanks in advance (and presume the plan's AE factors aren't going to override 417 minimums) --Bri"

"Maybe this is a simple question, but I'm having trouble wrapping my head around it and I've never had it asked before. I have a potentially new client who wants a 401(k) plan. They have union employees covered by a collective bargaining agreement. So the premise would be to exclude union employees from the plan, right? Except they also pay these union employees non-union income to cover their travel expenses. AND, one of the two owners works for the union as well. Part of me says, well that part of the income isn't covered under the collective bargaining agreement (or able to be deferred, matched, etc), so that income would automatically be included, and they would be eligible for the non-union plan for the income not covered in the agreement. But the (prototype) language that any employee covered by a collective bargaining agreement is excluded has me wondering. Your thoughts? (Thanks so much in advance!)"