"We use the RElius Corbel formatted document. Anyone have any idea what the normal procedures would be for how to treat rehires? One of the options listed below should be somehow selected or known. Can it be purely administrative policy or is there an absolute answer to this question contained somewhere in the BPD? I also understand (From reading the administrative provisions and BPD) that there is less flexibility if we are trying to use the 90 day permissible w/drawal EACA provisions.

Affirmative Election WAS Made [1] Do NOT auto enroll or resume any affirmative elections. [2] Subject the participant to a new auto enroll process. [3] Implement the old election on payroll.

Affirmative Election NOT made: [1] Do NOT auto enroll or resume any default elections. [2] Subject the participant to a new auto enroll process. [3] Implement the old auto enrollment rate on payroll without a new set of notifications/wait periods.

This option is more important of course if there is an auto escalation feature. Just curious if I'm the only who is struggling with this issue more and more as more plans add auto enrollment...."

"Someone recently asked me what effect cash basis vs accrual reporting would have on compliance testing, and I drew a blank because all our plans are accrual. Now I'm thinking depending on timing of deposits limits could be exceeded (402g, 404c, 415). Maybe issues with 410b? Anyone have any thoughts here."

"A new client who has engaged my office to provide Consulting Services, has a 401(k) plan since 2001, and now wants to move to a Pooled Employer Plan. Where can I find detailed information regarding the transfer, along with the applicable Notices, potential Black-out period, etc. As one knows if a 401(k) plan is terminated a new one cannot be started immediately as a 12 month waiting period is in play. How does the preceding impact the transfer to a Pooled Employer Plan. There does not appear to be enough information to properly advise one's client on how to proceed."

"There has been a lot of talk recently about some plans switching to use the full yield curve for funding purposes to save PBGC premiums, and enjoying an automatic IRS approval to do so. Is this really automatically approved for all plans/circumstances? Section 1.430(h)(2)-1(b) indicates to use segment rates for the month containing the valuation date. Alternately, under Section 1.430(h)(2)-1(e)(1) & [2] you can elect to use segment rates with up to a 4 month lookback. Most plan I've seen use segment rates with a lookback. Section 1.430(h)(2)-1(e)(1) further indicates 'Any election in this paragraph (e) may be adopted for a plan year without obtaining the consent of the Commissioner, but, once adopted, that election will apply for that plan year and all future plan years and may be changed only with the consent of the Commissioner.' So, it appears a plan that elected to use segment rates with a lookback does not get automatic approval to switch to the full yield curve under Section 1.430(h)(2)-1(e)(4). What am I missing here? Initially, I was always under the impression that you can have automatic approval to switch the full yield curve, but the analysis above seems to contradict that."

"I am a financial advisor (used to be a TPA) working with a small company with a pooled 401k account. The plan sponsor is terminating the plan. There are 2 life insurance contracts in the plan. One contract only has a cash value of about $450 so we'll ignore that for this purpose. The plan has been paying the premiums. However, the other policy which is on the owner of the business has a cash value of over $200k. That policy is paid up so no premiums have been paid on it for as long as I have been involved with the plan. The plan assets are pooled and valued quarterly. I noticed on the most recent valuation that the account balances that are being reflected and given to participants do not take the insurance into account at all. In other words, the value shown on the participant statements only equals the value of the plan investments exclusive of the life insurance contracts. Same for the most recent 5500 -- no accounting for the life insurance. The owner wants to take the cash value of his policy and roll it to an IRA. I feel like the insurance is an investment of the plan and that if it is surrendered, it wouldn't just go to the owner. But I am not sure on that.. ? This plan has been in existence since the early 70's. I don't know if the life insurance premiums for the owner's policy were paid from plan assets or charged directly against his account. Does that make a difference on whether the cash value of the policy all goes to him?"