"We have a potential new client where: Grandma owns 47% Mom owns 47% Third party owns the remaining 16% If they were to hire one of the grandkids, technically they wouldn't be considered an HCE based on attribution correct? My understanding was that ownership transfer from grandkid to grandparent, but not the other way. And since mom only owns 47% there isn't an issue. I just wanted to confirm I was correct. Thanks!"

"Have a sole proprietor with a profit sharing plan, would like to terminate and roll funds to an IRA. In looking through paperwork it appears there may have been 2 Plan ID's used.....checked both and do not see record of any 5500 filings. Plan was established in 2005 and, until recently, had more than $250K in assets each year. Only activity are yearly RMD's. Looking for advice on how to proceed."

"Has anyone seen language from FIS Relius? (Yes, I posted on that board as well.) Or any other source? I believe FTWilliam has a SECURE Amendment for its NQ plans but have not seen it; am also wondering if there is other amendment language available out there. The amendment is due to be adopted by year end."

"A BenefitsLink discussion yesterday remarked on a service provider's request for a nonelectronic signature, despite an IRS procedure that permits an electronic signature. There is no one comprehensive rule that answers questions about the acts or circumstances that require a manual, rather than an electronic, signature. For some of us, it's not easy to recall which acts (of those that call for a plan sponsor's or plan administrator's signature) permit an electronic, or require a 'manual', signature. So, let's crowdsource our list. The focus is on what the three U.S. government agencies -- the Treasury department's [IRS], the Labor department's Employee Benefits Security Administration (EBSA), and the [PBGC] -- say is permitted or required."