"I'm using the client's 9/15/24 extension for Form 5500-EZ, which I have not done previously for any client. Do I check 5558 at the top? I was thinking of checking 5558 at the top and including the Corporate extension as an attachment."

"For a single-employer individual-account (defined-contribution) retirement plan, typically the employer, or some committee or officer of it, is the plan's administrator. Of those, for some a bank or trust company is the plan's trustee, but for others only people associated with the employer are trustees. (For the question I ask here, let's leave aside an investment adviser, even if it is a fiduciary.) So, how often does it happen that both the administrator and trustee roles are filled by the employer? My query is only to support a lesson I teach my law school students. Any information you share I'll use only with nothing identifying, and only in a very wide generalization."

"401(k) plan participant dies. Spouse is sole primary beneficiary. Based on advisor's recommendation, spouse -- pursuant to SECURE 2.0 -- elects to treat 401(k) account balance as if she was the employee. Participant also had a SIMPLE IRA. Spouse is sole primary beneficiary of the SIMPLE IRA. With spouses having full rollover rights (402(c)(9)), is there any issue with spouse rolling over the SIMPLE IRA death benefits to the 401(k) plan and having the recipient 401(k) plan treat such rollover as if she was the employee for purposes of paying RMDs to the spouse?"

"Employer has history of reimbursing some COBRA for terminated employees being provided severance. Company is concerned about number of individuals on COBRA for general health insurance renewal purposes as well as with possible switch to a PEO with benefits. Former employees generally have no contractual right to COBRA reimbursement and there is no severance plan or program--the Company has just offered to reimburse some limited COBRA on a discretionary basis with past terminations. Company would prefer to avoid more COBRA beneficiaries if possible. Any concern in stopping the old COBRA reimbursement practice (maybe forever, maybe just temporarily) and implementing a new severance arrangement where the amounts provided for COBRA reimbursement are instead provided as special 'transition health insurance benefits' (or whatever you want to call them) for use in covering the cost of transition health coverage either through an exchange or COBRA and requiring proof of coverage? If that is a problem, any issue in simply providing that amount generally earmarked for transition health coverage but paid no matter what--i.e., they get the cash and can spend however they want without being limited to reimbursement. Employer would not limit ability to elect COBRA and would provide all required COBRA election packages but may highlight the potential benefits of exchange coverage as part of the exit process."

"I do have some very generous plans that allow deferrals immediately. Most concernedly, I have a MEP that allows it -- and now we're bringing on our first 10+ employee employer post-12/28/22, so welcome to automatic enrollment. Amongst all the other issues is timing for the automatic enrollment notices. Obviously, it's going to be difficult to give the notice before they are eligible. What is the best solution for implementing it? It seems counter to the intent to say 'Welcome to Company X. Since we are part of Y's MEP with immediate eligibility, you can elect to defer starting today, your date of hire. But if you don't make an election, then in 30 days you will be subject to the plans' automatic enrollment provisions as outlined on this notice I'm giving you today.' Is that really the way to go?"