"What are the options for adding a student loan match now in 2025 to a non-safe harbor calendar year plan? The plan has a payroll period based match. Would the student loan match have to start mid year for example 5/1/25 in order to be payroll based, even though it can be funded annually after 2025? I am thinking if they want to make the student loan match retroactive to 1/1/25 they would need to amend the match formula for all participants -- regular deferrals and student loan repayments -- to be an annual match and look at compensation and deferrals retro to 1/1/25. IRS Notice 2024-63 indicates the match has to be at the same rate. Thoughts?"

"Suppose a plan has eligibility requirements of 3 consecutive months with at least 250 hours. Let's make it easier and say age 21. The plan also excludes part-time employees. Part-time employees are DEFINED as per diem employees -- they are not defined by hours. All the 'part time' employees work <1,000 hours in a year. So, since the LTPT rules do not permit an exclusion category as a 'proxy' for avoiding the LTPT rules based on an age or service condition, it would seem that this exclusion class is not valid for avoiding LTPT deferral eligibility if such an employee satisfies the 2 consecutive year/500 -999 hour/age 21 requirements, although it should be ok for employer contributions, subject to testing. Or, if someone satisfies the 'normal' eligibility of 3 months/250 hours, even though they are excluded, do they NEVER become LTPT, because they have satisfied the less stringent normal eligibility requirements?"

"I want to be 100% for this particular client who loves Roth. I realize the plan could allow for Roth conversion as an option. But he may prefer to fund his employer contribution as Roth. I know it accomplishes the same thing but that might feel better to him. He is a sole proprietor and maximizes deferral and employer at 415. So I assume he could elect Roth for his safe harbor nonelective and profit sharing. I know it will be troublesome to have to allow this option for his few employees also. The plan is not on a record keeping platform so we don't have to worry about any limitation there. The plan already provides for employee Roth but not the employer Roth of course since that is SECURE 2.[0] Sound ok?"

"I have searched various websites without much help. The form 5500 site only goes back to 2010. If a Plan was supposed to terminate in the early 2000's but assets were never brought to $0.00, how do you find this Plan?"

"Employer sponsors a 401(k) Plan. Certain (now former) employees form their own P.A.s and sign joinder agreements so they can continue to participate in Employer's 401(k) Plan. Former employees want to keep their P.A. payroll deferrals semi monthly but actually deposit the maximum contribution via a single check from the PA before the deferrals occur. Is this a prohibited transaction?"