"I have a situation where client wants to terminate its 401(k) before a stock sale. Client uses a Fidelity preapproved document and has already adopted its restatement but is being told by its Fidelity rep that it needs to come up with its own good faith amendment for SECURE Act and CARES Act because Fidelity does not have yet and will roll those out only later this year. I have a form of good faith amendment that I can use for this client, but I am a little incredulous that Fidelity does not have its own by now. Can anyone confirm or deny what the client’s Fidelity rep is saying? This must have affected a lot of terminating plans over the last couple of years."

"To determine the amounts for 3-year 457 special catch-up that can be used at City B A government employee goes to work for City B in 2022 and wants to start making catch-up contributions at 457(b). Assume that he meets the NRA rules as defined in the at City B, Assume he can provide all the documentation from City A to City B He has underutilized amounts from City A prior to 2022 - let's just 2002-2022. He never really used the three-year catch up at City A anyway so it is true underutilized - no double dipping. Question: Can he use his underutilized amounts from City A 457(b) be used at City B Question: confirm this is a code specific interpretation and not something specific to plan provisions Citing the 457 code would be helpful. It appears that underutilized amounts are individual to the participant and a personal limit that can be carried from employer to employer. the catch-up can only be used once per employer but the underutilized amounts is not specific to the City B contribution history but to the City A contribution history as well"

"There are 5 Participants in Plan - Owner, her husband, their 3 over 21 and not disabled children. Both Owner and husband began taking RMD's. Owner dies in 2018, after RBD. Her husband is taking RMD's of her account. Husband dies in 2022, also after RBD. The 3 children are the beneficiaries for both accounts. Looking to confirm what I think the new rules are: Owner:

• 2022 - Paid as intended based on subtracting 1 from 2021 RMD factor used
• 2023 on - Must be paid by 12/31/32 to 3 children, using life expectancy of oldest son, then subtract 1 each year, w/bulk being the RMD for 2023

Husband:

• 2022 - Paid based on his age in 2022 using new table
• 2023 on - actually the same as for the Owner above

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