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July 2, 2025

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metsfan026 created a topic in 401(k) Plans

Form 5500 Reporting of Pre-Funded Contribution

"Question on how to handle a minor issue. We have a client who inadvertently deposited a 2025 contribution on 12/30/24 so it's showing up on the 2024 Asset statement. When filing the Form 5500 would you: [1] Show it as a liability to remove it from the assets [2] Just remove it from the assets and act like it was deposited on January 1 It's not a significant amount, just curious how others have handled it in the past."

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MeAgainst401K created a topic in 401(k) Plans

PTE 80-51 (Amended and Restated by PTE 91-38): The 10% Investment Limit

"PTE 80-51 and PTE 91-38 permit bank-maintained collective investment trusts (CIT) to engage in certain prohibited transactions with plan-related parties as long as the plan holds no more than 10% interest in the CIT and other requirements are satisfied. Entity A is a trustee of a CIT (so A is a bank that maintains the CIT), and an affiliate of entity B. B sponsors a 401K plan, holds less than 10% interest in the CIT. Both A and B are "parties in interest" for ERISA purposes. My reading of the PTEs is that since A is a bank that maintains the CIT and B is an affiliate of A (assuming B owns ~80% of A) fees paid to A or B would cannot benefit from the 10% rule. Has anyone else thought about similar issues?"

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