"I know the Secure Act forces plans to include part-time employees in the Plan. However, can a plan still explicitly exclude them as a group in the Plan Document as long as it passes all coverage testing? I thought we could, I just wanted to be 100% sure. Thanks!"

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"Plan as-written was participant directed but everything was invested in a pooled account. For a bunch of years. Currently, they are with a record-keeper and everyone is directing their stuff moving forward. What's the fix for the prior years?"

""Basically Green" posted an almost-identical question in November, but I have a slightly different scenario. My question is 'basically' (sorry, couldn't resist:)) - does the Code "B" in Box 7 indicate that the entire cash-out distribution was Roth?? If no, then I can safely prepare the 1 1099-R to report everything at once. Right? Details: My participant, age 26, took a cash distribution of his Roth deferrals and ER contributions. He did not make the 5-year mark to maintain tax-favored status on the Roth portion. 20% was withheld from the taxable portion of his distribution. May I prepare 1 1099-R, showing the gross cash-out amount in Box 1, the non-Roth/taxable portion of the total in Box 2a, and list his Roth deferral amt in Box 5? The codes I would use in Box 7 are: 1 & B. Here are exact details: $1414.87 total cash-out. $539.94 pre-tax & $874.93 Roth deferrals from 2022 & 2023. $107.99 was withheld. This is 20% of pre-tax portion. I'd put $1,414.87 in Box 1, $539.94 in Box 2a, $874.93 in Box 5, and a 1 & B in Box 7. Thanks!"