"DB Plan owner only. Plan effective 1 1 2014. Owner was working since 2003. Frozen after 12 31 16 year (3/1/2017 frozen) Avg salary 263,000. Terminating Plan now and overfunded. Plan provides to allocate excess assets to the participant up to the 415 limit. Is the 415 Accrued Benefit $5,250 (as the 415 benefit at 2016 was 17,500 and three years of participation at the freeze date of 3/1/2017)? Or is possibly higher due to increases?"

"Plan has assets with one of the big 401k vendors as well as outside pooled managed funds. Owner participant (who was already receiving RMDs, born in 1939) passes away. Past RMDs have been calculated by the TPA on the entire balance and distributed from the pooled managed funds. Spouse is the beneficiary and plans to roll the decedent's balance out of the plan to an IRA. Vendor wants to process RMD prior to rollover. Anyone ever been able to convince the vendor that the beneficiary can roll 100% of the account that they hold and the RMD will be made from the outside plan assets? I would think that if the Trustee of the plan directed them to pay out 100% of the deceased participant's account to the beneficiary they would have to do that. It will probably end up that the vendor will take the RMD anyway for their portion and then the TPA will calculate and have the Trustee pay the balance of the RMD from the pooled funds but it would be nice if the beneficiary only had to deal with one total RMD payout."

"Thoughts? 'After considering the public comments, the Agencies decided to adopt the proposed counting method change for defined contribution individual account plans by adding a new line item on both the Form 5500 and Form 5500-SF for defined contribution pension plans to report participants with account balances at the beginning of the plan year (there already is a line item for reporting the number of participants with account balances at the end of the plan year). Instead of using all those eligible to participate, defined contribution plan filers will look at the number of participants/beneficiaries with account balances as of the beginning of the plan year (the first plan year would use an end- of- year measure) when determining if they are eligible for small plan reporting options, e.g., the Form 5500-SF. Conforming changes are also made to the short plan year filings and the '80-120' Participant Rule instructions to reflect this new counting method. See Appendix C for details on changes to forms and instructions related to this audit related participant counting method change.' "

"I realize it won't be an issue right away - but does anyone know if the long term part-time employees contributing will need to be counted as participants w/balances for 5500/5500-SF purposes? I know they can be excluded from testing, but haven't been able to find information as far as the 5500 return counts. Thanks in advance!"

"Hello, I typically do the annual match calculation and lump sum contribution for my company in late January in the year following the plan year, but the company has a lot of expenditures in Q1. They have asked if the match could be paid later in the year like, for example June 30. I offered April 1, but they declined that date as it's too close to Q1. They countered with April 30 or later, like June 30. I believe a match paid after April 15 would mess up compliance testing, am I right? Especially 415 testing, which is an issue for my company as we do after-tax voluntary contributions/Roth conversions. I will offer to do quarterly matches with a last day of the quarter requirement. Right now we have a last day of the year rule. By going quarterly it will increase costs, but spread out the payments like they want. What does the community think? Is a match payment after April 15 not a feasible idea? Besides 415 testing, what other tests are impacted so I can defend my position?"