"I know Secure 2.0 had initially said that Hardship Distribution could be self-certified. Was that pushed back, though? I just want to make sure, as we had a client that had adopted that strategy, but I think we may need to backtrack. I just want to be sure."

"I've got a plan (only deferrals and SHNEC money) where the employer is undergoing an asset sale on 1/31/24. We were all set to terminate the plan on that date pursuant to the business transaction (so they can keep the SH for 2024). Today they asked if, since it's an asset sale and therefore they will 'retain the company' after 1/31, they can pay out bonuses after 1/31 through payroll (since they'll suddenly have a lot of cash and they are very nice to want to share it with some of their former employees) and how would it affect any plan calculations. It's not clear yet if they prefer it to be counted or not, but first I want to make sure I've got all the pros and cons right. I think that as long as the 'payroll date' is in 2024, it will get brought in as plan compensation under the post-severance comp rules (which are included for plan compensation). The employees are considered terminated on 1/31/24. Also, since they are retaining their entity (they are an LLC taxed as a partnership), they can effectively say it is open until 12/31/24 and therefore the plan also goes along with that. I'm fine with terminating the plan effective 12/31/24 -- it might even give the partners some additional income if they collect money during 2024. But if they want to terminate the plan, say, 6/30/24, do they lose the benefit of the safe harbor since at that point, the plan termination is no longer connected to the business transaction? I suppose they could give a 30-day notice at that point -- there are no active employees to get it, so they could just stick it in their files. I'm sure I'm overcomplicating this...."

"Can a DB plan be amended to permit in-service lump sum distributions and also cease future accruals for any person who elects to take a lump sum?"

"Does anyone have a generic special tax notice that they have been using that doesn't reference any recordkeeper names? Something special designed for TPA's for example? ... The IRS one has two separate notices, one for Roth and one for Pre-tax and that's, well, not workable."

"The end of December marked the end (at least for now) of my 41+ years in this business, starting as a part time DC system programmer (before I knew what a 'forfeiture' was) and ending as an Enrolled Actuary with all the ASPPA exams completed as well. I have also been a Benefitslink Board participant for more than 23 years. Here, as well as through the exams, is where I learned my stuff. I am grateful for the learning, teaching and helping opportunities (and more than a little fun) created by Dave and Lois Baker through this awesome system. Their efforts aren't appreciated enough. Thanks also to the countless Board participants that have educated and helped me over the years; and I hope I've been able able to help others as well. I still plan to linger now and then but goodbye and Happy New Year for now! Thanks again Dave and Lois."