Message Boards Digest

October 17, 2022

Here are the most recently added topics on the BenefitsLink Message Boards:

Lauren0507 created a topic in Retirement Plans in General

Late Adoption of Cycle 3 Restatement

"It is my understanding that the late adoption of the Cycle 3 restatement results in the plan losing its ability to rely on the preapproved document's IRS letter and the plan becomes individually designed beginning 8/1/2022. Further, this can be self-corrected under EPCRS so long as all of the requirements for self-correction are satisfied and the individually designed plan is compliant as an IDP. The employer may then rely on the preapproved document's IRS letter. My question relates to timing. It appears you must first correct any plan document failures then adopt a new Cycle 3 document.

Assume the client presents us with a Cycle 3 document effective 1/1/2022 and signed 8/31/2022. We review the prior document and find it is in compliance as an individually designed plan. Besides documenting in a Board resolution the employer's intention to self-correct what additional steps, if any, must be taken?"

1 reply so far   |    Click Here to Add a Reply

Pension Rights Center's Celebration of Karen Ferguson

Sponsored by Pension Rights Center
Please join us on October 26 in celebrating the life and legacy of Karen Ferguson - and the vibrant future of the Pension Rights Center. Come share a night of food, fun, friends – music and memories.

BG5150 created a topic in Form 5500

Any Written Set of Rules as to How IRS Plan Numbers Must Be Assigned?

"Is there a codified rubric that says how IRS PNs must be assigned? I have a MEP, do I have to have a PN that starts with a 3? Where is the written guidance?"

1 reply so far   |    Click Here to Add a Reply

metsfan026 created a topic in 401(k) Plans

Can a Consultant Paid via 1099 Sponsor a 401(k)?

"We have a consultant who came to us who wanted to start a 401(k). Technically he doesn't have a company, it's just him getting 1099 income for consulting. Can someone under that circumstance start a solo 401(k) plan and file it under their SSN? For some reason they don't want to do a SEP (haven't gotten a straight answer as to why)."

4 replies so far   |    Click Here to Add a Reply

ecphcs2 created a topic in 401(k) Plans

Rehire Scenario -- What If Rehire Occurs Outside of Initial 12-Month Eligibility Computation Period?

"Plan has 1 year of service requirement, and shifts eligibility computation period to calendar year after initial computation period. Employee hired on March 1, 2022 and then terminates on May 1, 2022. During that time period, worked 250 hours. Employee is rehired on June 1, 2022.

Does the eligibility computation period still shift to calendar year, even though rehire happens outside the initial 12 month period? I don't find this clearly addressed in the regs. It seems the better approach is to shift to calendar year, but is not clear."

4 replies so far   |    Click Here to Add a Reply

cheersmate created a topic in 401(k) Plans

Can Employer Deduct 2021 ACP Safe Harbor Match on 2022 Tax Return?

"Employer (S-Corp) extended its 2021 Tax Return to 9/15/2022, but filed it in April.

In March, 2022 the employer deposited its Safe Harbor Matching (ADP) contribution for the 2021 Plan Year. This contribution was deducted on its 2021 tax returns.

On September 15, 2022 the Employer deposited its Safe Harbor Matching contribution for the 2021 Plan Year and, because it had already deposited the requisite ADP Safe Harbor Match, would like to deem it the ACP Safe Harbor Match (as permitted by the Plan).

Can this contribution be deducted on the business' 2022 tax returns, or must the 2021 returns be amended to capture the deduction? The amount is well below 404 deduction limits and it is anticipated it will be well below the 2022 section 404 deduction limit if added to the 2022 plan year contributions."

2 replies so far   |    Click Here to Add a Reply

Here are the most recently posted jobs on, a service of BenefitsLink:

View job as Senior Retirement Analyst

Senior Retirement Analyst  View details

Dunbar, Bender & Zapf, Inc.
Remote / Pittsburgh PA

View job as Retirement Implementation Coordinator

Retirement Implementation Coordinator  View details

Remote / AZ / MI / MN / ND / NH

View job as Defined Contribution Plan Consultant

Defined Contribution Plan Consultant  View details

FuturePlan, by Ascensus

View job as Healthcare Actuarial Consultant

Healthcare Actuarial Consultant  View details

Remote / Indianapolis IN

View job as Retirement Plan Consultant

Retirement Plan Consultant  View details

Independent Retirement
Remote / ID / OR / WA

View job as Institutional Client Management Consultant

Institutional Client Management Consultant  View details

Remote / Greenwood Village CO / Tampa FL / Atlanta GA / West Des Moines IA / Minneapolis MN / Allentown PA / Raleigh NC / Charlotte NC / IL / NJ

View job as DC Retirement Plan Administrator

DC Retirement Plan Administrator  View details

Heritage Administrative Services, LLC
Remote / Woodbury NY

View job as Pension Consultant

Pension Consultant  View details

Pension Associates
Remote / Stamford CT

►View More Jobs

►Post a Job

►Get Instant Job Alerts, Inc.
56 Creeksong Road
Whittier NC 28789
(407) 644-4146

Lois Baker, J.D., President
David Rhett Baker, J.D., Editor and Publisher
Holly Horton, Business Manager

Copyright 2022, Inc. All materials contained in this mailing are protected by United States copyright law and may not be reproduced, distributed, transmitted, displayed, published or broadcast without the prior written permission of, Inc., or in the case of third party materials, the owner of those materials. You may not alter or remove any trademark, copyright or other notices from copies of the content.

Links to web sites other than and are offered as a service to our readers; we were not involved in their production and are not responsible for their content.

Unsubscribe | Privacy Policy