"For an individual-account retirement plan with participant-directed investment that gets Ascensus' recordkeeping services, the plan's sponsor (which also is the plan's administrator and trustee) is considering adding a Schwab Personal Choice brokerage window, restricted to mutual-funds-only. Unlike other employee populations in which only a relatively few participants use a brokerage window, almost all participants would use the mutual-funds window. The employer pays Ascensus' fees for all still-employed participants, and likewise would pay Ascensus' incremental fees for pulling the brokerage accounts into the recordkeeping. The counts of participants, all of whom have a plan account balance, are such that the plan every year will require an independent qualified public accountant's audit of the plan's financial statements. An Ascensus-aligned trust company is the plan trustee's custodian. The plan does not use Ascensus or a TPA to test coverage, nondiscrimination, or top-heavy measures. BenefitsLink neighbors, what difficulties should I advise this plan sponsor to consider in its decision-making about whether to add the brokerage window?"

"Is this even possible? I didn't think the IRS did any Advisory letters for 'pre-approved' plans that early. Have NOT seen the actual document or IRS letter to confirm what the audit firm is saying...."

"We're dealing with excess assets from a terminated traditional defined benefit (DB) plan that are being moved into a 401(k) profit sharing plan as part of a Qualified Replacement Plan (QRP). Can the QRP funds be moved into a cash or money market account earning little or no interest while the rest of the plan's assets remain invested? This is a one-participant plan, not sure if that makes a difference. The existing plan assets are invested in volatile securities, and the account owner is concerned that market swings in the suspense account could prevent us from using up all of the QRP funds within the required 7-year period. I couldn't find anything indicating that QRP funds must be invested in the same way as the rest of the plan -- does anyone know if that's a requirement?"

"Before this plan came to us, there was a partial plan termination. Many of the accounts were distributed, but not all. Those that remained just were given accelerated vesting. Do the accounts of participants involved in a partial plan term HAVE to be distributed? Or can they stay in the plan?"

"2019 5500-EZ was filed with less than 250k in assets for the first year of the plan/filing but stopped filing in subsequent years and assets are still under 250k. Was there a continuation requirement because initially it was filed?"