"My firm just took over a plan that missed the PPA restatement & the cycle3. We have completed both restatements now but what do we need to do to correct this? Ours thoughts were that the PPA document needs to be corrected through the VCP and that cycle3 could be corrected through SCP. Can anyone confirm or share their thoughts? There is some varying information out there."

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"Can a participant's enrollment be changed if they failed to inform the employer of a dependent's ineligibility during the special enrollment period? The participant presented a 'nonsuit' to the employer that indicates the participant, as of February 2025, is no longer proceeding with formally adopting a child. The participant divorced his spouse in 2024 and the ex-spouse is currently receiving COBRA. Assuming the nonsuit constitutes a qualifying event, the participant did not present the nonsuit to the employer until after the end of the special enrollment period. The employer has been made aware that the child is ineligible because he/she is no longer a dependent of the participant. Coverage by the insurer for the now ineligible dependent can be dropped prospectively; however, can the participant's coverage be also be changed from Employee + Dependent to Employee Only given that he no longer has a dependent? What about COBRA? Who should receive the notice? The participant or the participant's ex-spouse who is proceeding with adopting the child?"

"I have a 401(k) Plan with the following eligibility conditions: deferrals & SHNE, Age 21 & 6 months, immediate entry upon eligibility, profit sharing, Age 21 & 1 Year of Service, entry 1/1 & 7/[1] The Plan document reads 'For allocation purposes of the 5% Gateway Contribution described under (A) of subsection (iii) above, 415 Compensation shall be determined for the Plan Year (rather than the Limitation Year) but shall exclude 415 Compensation paid while an Employee is not a Participant in the Plan.' (It's a Relius document.) 

"I have 3 individuals who were participants in the deferral and SHNE components of the Plan for the entire year, but entered the PS component on 7/1, so they have partial year excludable comp for a particular Plan component, but they've received 401(a) contributions the entire year. Is their 5% gateway test compensation based on their post-PS entry compensation or their full year comp? 

"An additional question boils down to is compensation paid prior to participation in a certain component of the Plan a 414(s) safe harbor exclusion or is it only compensation paid prior to overall Plan participation? Does it matter if two different components which are both 401(a) contributions have different pre-participation compensation amounts? Even more simple question, can someone point me to where pre-participation comp as a 414(s) safe harbor exclusion originates? I've found lots of articles saying so, but I seem to be reading past the primary source language listing this."

"There must be some website where I can download the APRs for cross-testing, right? There should be tables for each mortality table and different interest rates. I know I can export them one at a time out of Relius but I am assuming some website has them somewhere?"

"Plan is a 401k PSP pooled account. The trustee and her spoiuse both took out 2 loans a piece and defaulted on both of them. One in 2022 and one in 2023. Their CPA issued the appropriate 1099s. There is a zero balance showing for their loans. They want to pay the balances off. Can they do that?"

"Deferrals/SH: age 21, 2 months, quarterly entry PSC: age 21, 1 YOS, Immediate entry both SH and PSC exclude pre-entry compensation if an employee who became eligible for def/SH on 7/1/2024 with a pre-entry compensation. since he is entitled to SH, then he needs to get GW min. we use 5% GW test method which allows us exclude pre-entry compensation. can I use the SH post entry compensation for GW min calculation in this case? or we have to use full year compensation for GW since the post entry comp is for SH but not PSC?"

"Is a plan amendment required prior to 1/1/2026, or does this just fall under the general SECURE/2.0 amendment deadlines -- in other words, it can be handled operationally as long as amended by the deadline? Recognizing, of course, that notification will need to be given to the HPI's as well as participants who will now have a Roth option if they didn't have it before, etc."