"[An] employee terminates employment on May 2, 2024. By the terms of the fully insured policy, coverages ends on May 31, 2024.... [M]ost plan sponsors would continue 'active' coverage through May 31, then send a COBRA notice stating that they are eligible for COBRA starting on June 1, 2024 (and ending 18 months from June 1 and not from May 2).... [T]he COBRA rules default to an 18-month period based on the date of the qualifying event (here, termination) even if the loss of coverage occurs on a later date. However, the regulations allow plans to measure the 18-month COBRA period based on the date of the loss of coverage following the qualifying event.... [M]ost available wrap plan documents and policies either don't squarely address the issue or simply state that participants are eligible for COBRA based on a qualifying event without additional clarity (maybe by design). In practice, ... starting a full 18-month COBRA period on the day after the loss of coverage (June 1, in the example above) is far more prevalent, whether intentionally following the regulation or just out of routine."

As I never came across one (nor dealt with 412e3 plans for over 10 years), how does one calculate RMDs?"

"Plan sponsor has had 401(k) plan in which a participant is 100% vested in profit sharing. He wants to adopt a DB plan for 2023 and the employee terminated in 2024. Can years of service be prior to DB adoption be excluded for DB vesting? The plan document says service for vesting must be recognized for a 'predecessor' plan. Does predecessor include K plan or only a prior DB plan?"

"Employer contribution for 2022 of about $9,000 was paid in Sept 2023 in time for tax deduction purposes. The plan is a dreaded separate brokerage account for each person, granted a small plan. Despite us providing the participant allocation of the money to the broker (more than once -- the brokerage firm had personnel changes) they did not implement the allocation so the funds sat in an unallocated account until just now. The broker is asking about makeup earnings. While that seems to be the right thing to do, I'm not certain it is required. It is likely a fiduciary issue.... Thoughts?"