"To satisfy the new secure 2.0 auto-enrollment feature QACA arrangement would be considered an eligible automatic contribution arrangement if the QACA contained a provision that would allow an employee to do a permissible withdrawal? Is there anything I'm missing here?"

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"If an allocation of stock is originally based on compensation, but then adjusted several times in order to pass 409(p), does the resulting allocation need to be tested as though the plan was using New Comparability?"

"Had an actuary ask me about Code 4980's text of: (I) allocated under the plan to the accounts of participants in the plan year in which the transfer occurs, or (II) credited to a suspense account and allocated from such account to accounts of participants no less rapidly than ratably over the 7-plan-year period beginning with the year of the transfer. and whether or not that means if the final transfer of excess assets occurs today in mid December, that at least one-seventh of the money has to be posted to accounts by 12/31. I suggested that the allocation date is going to be 12/31 even if that means waiting until the 2024 census is ready and the PS allocations determined some time over the winter. As opposed to actually being posted to accounts for participants in the DC plan by 12/31. I think (II) covers the issue, even if (I) didn't. But 'allocation' includes as a receivable, no? (Whether or not (I) would be enough argument....)"

"I have a terminating Defined Benefit Plan with assets in a pooled account at Vanguard. I prepared my standard Letters of Authorization for the Trustee to sign and submit to Vanguard for the benefit payments. Vanguard said the Letters were not sufficient but did not provide any alternative. Does anyone have a form or template that they have successfully used to get payments made from a qualified plan with Vanguard?"