"A participant in a 401(k) is taking RMDs. The participant would like to start using her RMD for a Qualified Charitable Donation, so she sets up a direct rollover of the 401(k) account to a new IRA so a portion of her 2025 RMD can be a QCD. (The 2024 RMD was taken before the rollover was processed.) The recordkeeper will only process rollovers as paper checks. The distribution was processed from the 401(k) but the recordkeeper said it is likely that the participant will not receive the check until after the end of the year. If that happens, the 401(k) will have a $0 balance on December 31, 2024 and so will the IRA. Is the date of the check from the 401(k) distribution sufficient to use that balance as the 12/31/2024 balance for the new IRA so the 2025 RMD can be processed from the IRA?"

"Have a client with seasonal layoffs this time of year. A participant wants to request a loan but is currently on lay off. Since the loan policy requires repayments be made through payroll deduction, is the Sponsor ok with denying this loan until the participant returns to work? With the nature of this business, the client should address this is in the plan loan policy but at this time has the stock loan policy from the Plan Doc, which does not specifically address this situation."

"First year of the plan. HCE's will be limited to 5% and prior year testing. HCE salary is 100k so max 5% is 5k. HCE is over 50, can they do additional 7.5k of catch-up and still pass ADP?"

"Ignoring the fact that some of these ostensibly non-ERISA deferral only plans don't really qualify as non-ERISA... Let's assume they qualify. Mandatory auto-enrollment in 2025 shouldn't apply, correct?"

"I am only familiar with Form 945 being used to reconcile taxes withheld and paid from retirement plans during the year. Is there another purpose for this form that an employer may need it for outside of retirement plan taxes? A client received a rather odd call from the IRS (I was not on the calls but I believe the phone number is legit and it was the IRS). They are telling her that she has not filed form 945 for years 2020-2023 and that even if no taxes are reported on it, it is still due and that if not filed, a $2,500 penalty will be incurred for each year. Even odder, they are saying there is no letter or correspondence that they can send. The plan utilizes a national retirement plan distribution service which accepts the 401k distribution, remits the taxes electronically, issues the 1099-Rs and also files a 945. But the 945 is filed under the service providers name and EIN, which is submits along with presumably hundreds of other non-related clients. The IRS caller was made aware of that and insisted that they need a separate 945 for my client, using their name and their EIN. Has anybody come across this before?"