"A terminating plan has a few participants who were terminated 6 to 10 years ago. They still hold a balance. I believe they should be 100% vested, correct?"

"I've been using this website to obtain covered comp data for calculating EBAR's: actuarialtools.com -- It doesn't seem like it's been updated yet for 2022. IT says 'updated for 2021' so I know it's not just me missing something! Does anyone else use this tool, and/or know when it will be updated? Or does somebody have a link to another table that they could share with me that has been updated for 2022?"

"When offering a lump sum window, I understand that a sponsor is required to also offer eligible participants an immediate annuity that satisfies the QJSA rules. However, I generally see lump sum window designs that limit the annuity options for participants who have not yet attained early retirement age to the QJSA (or QOSA), while providing the full suite of optional forms of benefits to those over early retirement age. Is that legally required (perhaps based upon the anti-cutback rules), or simply a design choice? Could all lump sum participants (who are not otherwise eligible for a distribution) be limited to the QJSA/QOSA?"

"A plan has 2 owners. Only employees who are HCEs have rollover money in the plan, do I count their rollover balances when determining how top-heavy the plan is? I would think not."

"I was asked by a financial advisor of a single member client just now: 'Should the plan issue a 1099-NEC to a person who did some work on the property the plan owns?' Thinking it through I would say yes. I would also guess that whatever account pays the RE tax bills would be the account that issues the 1099-NEC. Anyone have a quick answer? Of course the 1099 was due yesterday."