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August 6, 2025

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Coleboy1 created a topic in 401(k) Plans

Trustee Was Killed

"One of my clients was killed. He was also the trustee of the 401k plan. A new trustee was appointed and an amendment was done. The resolution did not address removing the old trustee as I didn't think it needed to be addressed since he was deceased. Should I have had some language addressing the removal of the deceased person as trustee?"

6 replies so far   |    Click Here to Add a Reply
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ERISA guy created a topic in Health Plans (Including ACA, COBRA, HIPAA)

SMM Required for Excepted Benefit Dental Plan?

"Does ERISA's requirement to provide SMM for material reduction on accelerated basis (within 60 days) apply to excepted benefit dental plan?"

1 reply so far   |    Click Here to Add a Reply

rocknrolls2 created a topic in Health Plans (Including ACA, COBRA, HIPAA)

Personal Benefit Account Providing Medical and Other Benefits: Is It an HRA for Section 111 MMSEA Reporting?

"A client has a VEBA that provides for certain benefits including a personal benefit, which is an individual account that is funded exclusively by employer contributions. The assets in the account can be applied to pay for medical benefits to the extent not otherwise covered under the primary medical plan, severance benefits, supplemental unemployment benefits, disability benefits, scholarship benefits for dependent children for post-secondary education or for payment of premiums for COBRA Coverage or retiree medical coverage. The questions is whether the personal benefit account is an HRA It walks like a duck in that it is totally employer funded, quacks like a duck in that it can be applied to reimburse medical expenses and pay certain medical premiums, but, if it goes into the pond for a swim, its feathers are all wet and it cannot fly for at least 30 minutes after it emerges from the pond -- to the extent that it pays more than eligible medical benefits. IMHO this is NOT an HRA and would not have to do Section 111 filing with CMS. Thoughts?"

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thepensionmaven created a topic in Form 5500

How to Find Record of DFVC

"I believe we filed a DFVC for a client, but did not snapshot each page. Is there any way to check if it was filed and if in fact, did go through? I can't believe they do not have a database."

2 replies so far   |    Click Here to Add a Reply

metsfan026 created a topic in 401(k) Plans

Form 5500 Mistake on Participant Count: Amended Form Needed?

"Just curious how people handle this, because I've had it multiple times where I client inadvertently doesn't give us a Termination Date on the Plan Census. So this leads to the participant count being incorrect (for instance, someone terminated in '23 but we weren't notified so they were included in the Active Count). Do you: [1] File an amended '23 form, to correct it? [2] Just file the correct count for '24 and ignore the '23 issue? [3] Carry the mistake forward for consistency, but have the Year End numbers correct for '24? Obviously the easy thing is to just amend the '23 form and move forward accurately, but I was just curious how everyone handles this."

2 replies so far   |    Click Here to Add a Reply

thepensionmaven created a topic in 401(k) Plans

Mega Back Door Roth

"Where can I find out more about Mega Backdoor Roth?"

3 replies so far   |    Click Here to Add a Reply

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