"A plan allows rollover contributions once an employee becomes eligible at 3 mos of service. If the recordkeeper inadvertently allowed 2 rollovers prior to the participants being eligible in the past year, is a retroactive amendment allowing rollovers immediately sufficient to correct this?"

"Have a company (a) that acquired company (b) via a stock acquisition. Company B terminated the plan prior to acquisition. It has been found that company b filed form 5500, but stated in part VII that assets were both distributed to participants, as well as transferred to A's plan in 13c(1). Would it make sense to have company b amend this return? Further any issues with company a ignoring even though company b administrators work for them?"

"On April 30, Empower announced the Empower S&P 500 Index Separate Account, a zero-expense fund to track the S&P 500® index. It’s available to a retirement plan (but not a § 403(b) plan) that’s an Empower Workplace recordkeeping customer. If a plan is a target of this offer and has an S&P 500 index fund in the plan’s investment alternatives, is there any reason a plan would not want this zero-expense fund?"

"This question involves a 403(b) plan, but should apply equally to other DC plans. So, employer wants to change to a 18-month cliff vesting schedule. Not sure this would necessarily work using the standard 1,000 YOS for a year of vesting. An employee could easily have 1,000 hours in less than 6 months in year 2, then terminate, so the "18 month" requirement wouldn't work. So, what if they use elapsed time. Seems like using one of the "other" options in the adoption agreement, and using elapsed time, you could use 1.5 years (and yes, service spanning could come into play) but I think this would be allowable. Am I missing something? (And I'm not opining as to whether this is advisable or not, just if it is allowable.) Any/all comments are welcome!"

"401k plan match was provided in 2023 when participant wasn't yet eligible (90 day mark wasn't hit until Jan 2024). Participant has been advised that a year timeframe is when it was supposed to be corrected, they were advised that ERISA guidelines do in fact apply to ERCPS in this case, and that the timeframe for adjustments has passed. Plan admin is advising that an “excess allocation” which must be corrected in accordance with section 6.06(2). An Excess Allocation is corrected in accordance with the Reduction of Account Balance Correction Method set forth in this paragraph. Under this method, the account balance of an employee who received an Excess Allocation is reduced by the Excess Allocation (adjusted for Earnings). Who is right? And furthermore if the correction is to be made, is the proper method to pull distributed funds from the account immediately?"

"I have to send in a ticket to inquire about this. But, if you are restating effective, say, 1/1/2025, but you have one or more provisions in Appendix A with a different date (for example, adding Roth provisions effective 1/1/2026) the Reference guide, and more importantly, the Summary of Plan Provisions do not properly reflect this - has to be edited manually."