"Plan currently provides that all participants receive a SHNEC. The 100% owner wants to make a PS contribution but the test results are destroyed because her participating daughters are getting a SHNEC -- would there be any BRF issues if the plan is amended to just give the NHCEs a SHNEC? I can't recall if BRFs are ever an issue if it's just the HCEs that would ever get affected by an amendment."

"A client needs to bring his father over to live with him due to his age and health. There is a rollover account with plenty of money in it but the client is only 57. The renovations needed to make the house usable I guess is a lot ($100K+... I didn't ask why so much). There is already a personal loan in place and I don't know if you can call pulling that much out of a plan a hardship. I've looked and there is no exception to the 10% early distribution penalty. Is it as cut and dry as that? There is nothing he can do or say to be spared that added 10% for his noble effort caring for his elderly dad? Roll out some of his rollover account to somewhere and then pull what he needs without an early dist penalty from there? Trying to think outside the box at this point."

"Hypothetical question. Law/IRS says as long as the account is cleared prior to 3/31/2025, you do not need to restate the DB plan (required amendments aside). Plan DOT 12/31/2024, all assets distributed by 2/28/2025. On 4/2/2025, a dividend shows up in the account, amount not relevant. Rolled out sometime in April/May -- not informed timely. Is restatement now required?"

"Should Accrued Interest be included in actuarial asset?"

"A participant terminates employment and is automatically cashed out into an IRA by the recordkeeper. The individual was less than 100% vested, so forfeited his unvested funds. The individual is then re-employed and wants to repay the rollover in order to have his forfeited funds reinstated. He rolls over most (but not all) of the distributed balance back into the Plan, but there is a catch. Some of funds which were automatically distributed from the plan were Roth, but the plan does not accept rollovers from Roth IRAs. So while the participant did not fully repay the distribution, he did repay all that was technically allowed to be repaid back into the plan. I'm leaning towards the position of reinstating the participant's forfeited amount since they did transfer back all that was allowed by the plan. Any other thoughts?"