"ERISA does not bar plans from obtaining a line of credit/loan from a bank or other financial institution, but assuming the bank is a party in interest, is there consensus about the ability to rely on 408(b)(17) service provider exemption (adequate consideration requiring reasonable interest rate/terms)? And if collateral is required, do parties take the position that posted collateral is not plan assets, similar to collateral posted for derivatives?"

"A Solo 401(k) plan is part of a controlled Group. The owner of the company owns 100% of another company. He is not paid through that other company but has 2 employees. The owner is not contributing anything to the Solo 401(k) in 2024, but he did not tell his employees in the other company about the 401(k) Plan and that they are eligible. What would the correction process be? Based on this link, it looks like the correction method is to fund the average deferral rate of participant's group. However, nobody is receiving any contributions in the Solo 401(k) plan. Would there be no Missed Deferral Opportunity in this case?"

"I of course know about the ERISApedia and JH free webinars. I need more than I've been able to get through that. I do try and do the ASPPA spring/winter virtuals as well. Any other suggestions out there? I need this for ERPA designation."

"The Plan has a number of real estate properties held under the trust, including several that receive rent payments. I believe that rents received from assets under the trust a part of the investment return. My logic is that the properties are owned by the trust, and any rents received would be 'investment earnings' and not contributions. Am I off base?"

"I'm not as familiar with Governmental Plans, but have a governmental hospital who is wanting to exclude a class of employees who choose to receive a higher compensation and give up their rights to participate in the plan? Is this allowable? I know they aren't governed by ERISA, so I wasn't sure what classes of employees could be defined to be excluded in the plan document. This hospital has a 457(b) and a separate 401(a) for the employer match."

"Holding company has 15 wholly owned subsidiaries which all have separate qualified plans (mostly 401k plans). Does anybody have any tips/tricks for simplifying the process of performing (or avoiding?) coverage (and other?) testing across the controlled group?"

"I know that almost all DB plans provide that the 3 highest salary years for the salary average must be consecutive. However, is it allowed to provide for the salary average to be any 3 highest years, even if not consecutive. A bit generous, but for an owner only plan it might be preferred? It appears that if not consecutive the it creates a definitely determinable issue?"

"Plan is terminating and the termination date is 07/31/2025. The Plan sponsor wants to do a annual employer match true-up contribution which usually occurs in Jan for the previous year. They calculate the match throughout the year on a pay-check-by paycheck basis. [1] Since the plan is terminating I believe they should calculate and contribute to the plan for the period Jan 01-July 31 it will be for a short plan year correct? [2] Should they wait until next year to do the contribution or can they do the calculation now and contribute?"

"So, as far as I can tell, an 'applicable collectively bargained plan' means maintained under a collectively bargained agreement ratified before 12/20/2019. Does this mean that if the agreement is 're-ratified' -- or more recent than 12/20/2019, then the amendment deadline is 12/31/2026, as opposed to 12/31/2028? It would seem so, although that doesn't make a lot of sense to me...."