"DB plan -- one lifer. Client takes full annual RMD on 4/1/2023 instead of monthly (12x). Client decides to terminate the plan today and wants to rollover prior to 12/31/2023. No further RMD is due, correct?"

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"ARA requests immediate administrative relief in the form of of delay of application and enforcement of LTPTE rules."

"Is Life Insurance permissible in a cash balance plan? If yes, how is the 'incidental' limit calculated? Is it 100x projected benefit as in DB plans, or a percentage of contribution? Is it discriminatory unless policies all purchased on all participants?"

"Fully-Insured group with a section 125 plan. They have different employer contributions for Salary & Hourly employees in the same geographic location under the same EIN. The employer is Large Group so they have a 4 tiered composite rate structure and the contributions for the Salary & Hourly employees are:

• Hourly - EE 75%, ES 75%. EC 75%, FAM 75%
• Salary - EE 100%, ES 75%. EC 75%, FAM 75%

"The Hourly group doesn't have any HCPs and the Salary group has many HCPs so at first I thought this would be discriminatory since the contribution scheme favors the group with HCPs. My question is, Since the salary employees in the EE-Only tier are getting 100% of their benefits paid for would they be excluded as participants in the section 125 plan? If that group of EE-Only salaried employees is removed from testing then the remaining employees are all provided uniform employer contributions. Would this pass nondiscrimination testing?

"One concern I have is that a salary employee can be in the EE-Only Medical tier, but then have a Child they are covering on Dental in the EC tier and that pre-tax dental deduction would loop them back into the section 125 testing."

"Under 20 hours/week is roughly equal to 1000 hours/year. Our 403(b) plan would by definition possibly exclude individuals who work 500-999 hours, which would fit the LTPT classification. Based on the guidance that was recently released, I would conclude that LTPT applies to any 403(b) employees who have been kept out of the plan but who have worked 500-999 hours each year since 2021. They would have to be provided with the opportunity to contribute to the plan. Would you agree?"

"Since partners deduct their own profit-sharing contributions on their own personal returns, is the funding deadline for a partner the due of the personal return or is it the due date of the partnership return?"

"I need clarification please on the rules related to unforeseeable emergencies under eligible 457(b) governmental plans. What are the requirements for exhausting all plan distributions and loans first? I've read Reg. 1.457-6(c) (ii) ' distribution on account of unforeseeable emergency may not be made to the extent that such emergency is or may be relieved through reimbursement or compensation from insurance or otherwise, by liquidation of the participant's assets, to the extent the liquidation of such assets would not itself cause severe financial hardship, or by cessation of deferrals under the plan.' I believe the plan document can require a cessation of deferrals, but the language is not specific concerning a requirement to take a loan first and exhaust other available money sources in the plan such as rollover money or age 59 1/2 funds if applicable. Is this an option that a plan document could require, or is it basically required under the 457 regulations, or can it be an administrative requirement of the recordkeeper?"

"A participant in a qualified plan, stopped making loan repayments in which after 90 days the loan was deemed and reported on a 1099R the following year. The active participant would like to borrow again from the plan, the plan allows for one (1) per participant at any time, is the participant permitted to take a brand new loan? Or will he be required to pay-off the prior deemed loan first before he is able to initiate a new loan?"