"414A(b)(4): An eligible automatic contribution arrangement meets the requirements of this paragraph if amounts contributed pursuant to such arrangement, and for which no investment is elected by the participant, are invested in accordance with the requirements of section 2550.404c-5 of title 29 [ie., a QDIA] ... Are pooled trustee directed plans gone for good? That's too bad because they were a real cheap way of getting a small 401k plan in place. Participant direction is expensive (investment advice, recordkeeping, etc). Also what if the pooled plan was invested 50/50? Isn't a 50/50 option eligible to be used as a QDIA?"

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"Owner only DB plan, wants to terminate and distribute during 2025 Already turned 73 during 2025 i.e. first RMD is due 4/1/2026. Needs an RMD during 2025 i.e. split the distribution between rollover and RMD? In a different scenario for the same owner, plan is overfunded but only wants to rollover the full benefit and keep the plan open as will hire others to eat up the overfunding. As this in-service distribution will happen during 2025, is it subject to RMD during 2025 i.e. before the rollover?"

"I need to have the plan sponsor clarify if they are being acquired through stock purchase or asset purchase. I believe if asset purchase, employees of the acquired company are considered terminated and the plan can terminate and distribute. But if corporate merger through stock purchase, my understanding is employees are not considered terminated and that the acquired company plan can either be merged or terminated but 401(k) elective deferrals may not be distributed since there is a successor plan. I'm questioning if even safe harbor and profit sharing can be distributed since employment has not terminated and thus no distributable event and so perhaps the entire plan must merge into the acquiring company plan."

"We have a tax client (not a TPA client) who is a participant in her medical K plan and a hospital 403(b) plan. Turns out her deferrals for 2024 between the plans are $10,000 over the 402(g) limit. My understanding has always been (and confirmed by ChatGPT) since not corrected by April 15, the amount is taxable for 2024 and in the year distributed. But also that it must be distributed and I assume as reasonably soon as discovered. Someone else here asked CoPilot and it says it does not have to be distributed but is taxable whenever it is. Comments? We all know we need to check AI for correctness."

"Recently took over administration on a plan and discovered there is a participant that passed away in 2020 with an outstanding loan balance that was never offset. Would you offset the loan current date and issue a 2025 Form 1099-R to the participant's estate?"