"I am now going thru an exercise since I found out I was delinquent un filing the requisite form (5500). Since the threshold is 250K, should I be filing for those years only when my plan assets were above the threshold or do I need to file or all the years, since the plan began? I am assuming once I file for the specific starting year, I will file continuously as the plan assets have been above 250K!"

"Suppose you have a small 401(k) plan that has been in place for 10 years. There is an employee who has worked about 700 hours per year for 4 years now and has never been eligible because of the one year / 1,000 hour requirement. My understanding is that the plan does not need to provide employer contributions but does need to offer the employee the ability to fund salary deferral contributions. Question: Can the employer fund 3% of salary contributions to LTPT employees if it wants to? If so, would those employer contributions be subject to the gateway and rate group tests of 401(a)4? Employer contribution test of 410b? I would think not because those contributions are not mandatory to begin with."

"The recently proposed regulations state that plans may include a provision deeming high-paid individuals (HPI) as having irrevocably elected to have their catch-up contributions treated as Roth. Should this provision be incorporated into the plan document itself, or should it be added as part of the SECURE 2.0 amendment?"