"I have a potential client approach me with the following situation: Established a Solo 401k in 2021 (he was only employee) & contributed for 2021, 2022. He hired a full-time employee in the beginning of 2023. The eligibility requirements (if relevant) were non-existent in the Solo 401k document (immediate entry). For 2023, contributions were made & deducted for the owner, nothing for the EE. For 2024, contributions have been made already for the owner. What are his options for both fixing 2023 & making sure that the contributions made for 2024 are allowable? If I open a Qualified Plan effective for 2024, can he make the contributions for the EE covering both years? Essentially, is this something that falls under the ability to 'self-correct'?"

"I was on my wife's HDHP with an HSA in January 2024 when I started a new job January 3rd 2024. My benefits started February 3rd 2024. I started a FSA with my benefits thinking since we had our own health plans that it was okay. I was wrong. I know my wife will need to return of excess since she has been contributing to the HSA. I need to know if she needs to return the money that her employer put in and her contributions in January 2024 since my benefits didn't start till February."

"I don't know how to turn the 417(e)(3)(B) factor that is published each year into a formula that would convert an account value into single life and J&S 100% survivor annuity forms at age 67 (or older age if the person is older than age 67). I've got clients who self administer their DC plans and they need to come up with the hypothetical annuities each year (with December 1 assumptions and December 31 account values) for the required SECURE ACT ERISA 105 disclosure. Is there a formula to convert lump sums into the annuity equivalents with the 417(e)(3)(B) assumptions that DOL requires? Even better, is there an easy conversion table like we see with 401(a)(9)? For example, Notice 2023-73 says that at age 67 there is a factor of 0.00920. How do you turn a lump sum into the single life and 100% jt and survivor annuity equivalents? There is a great calculator on the DOL web site, but it generates annuity equivalents that cannot possibly satisfy the Department's 105 guidance. It grossly understates annuity equivalents and must still be using the outdated 10 year CMT rate that was much lower in 2019. Actuarial firms I contacted are charging outrageous amounts. Is there some way to do this without hiring an actuary? Frankly, I'd like to learn. Converting a lump sum into annuities for a fixed term is easy. It's generating a SECURE Act mortality table for age 67 and later years that has me stumped."

"A non-owner participant, DOB 01/22/36, terminated on May 10, 2022. His RBD was 4/1/23, I believe. His RMD forms were forwarded in late 2023 to the plan contact when I learned of his termination. The contact never returned the forms because she never heard from the participant. It turns out he died on May 5, 2022. Primary Beneficiary was his wife, DOB 2/6/40. Turns out the wife died March 18, 2023. Her Beneficiaries are their two adult sons. Questions: [1] I am right to think that since participant died before his RBD, no RMD's are required for 10 years? (Per a certain webcast) [2] Since the wife died before his RBD, are the distributions still delayed for 10 years? Is the wife now considered the participant when using the tables? Which table? This has stumped me and my colleagues. One colleague suggested that this is pre-SECURE, so the old rules apply, which really confused me."