"A plan sponsor from time to time rehires employees -- sometimes several months, sometimes 3 or 4 years after being terminated. These employees occasionally were participating in their 401(k) plan prior to their termination and are deemed to be participants immediately when rehired in almost all circumstances, according to the plan document. The sponsor has asked whether it would be possible to force such rehires to meet the eligibility requirements all over again after they are rehired if they were previously terminated at least a year before their rehire date -- I'm thinking it's probably impermissible to do this. They're currently using an FT William doc coded for the basic rule of parity provision, however, the program allows for modifications as an open entry item, i.e., anything at all can be written in to customize this provision, and the question of whether amending the plan to use this open entry item to enforce the one year restriction mentioned above arose. Is it legal to force requalification for such rehires after being away only one year?"

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"New plan being set up. The EIN request was submitted and granted with an old address. Having never been used yet, is it a big deal to just forget the first EIN and get a new one? Or file form 8822b to correct the address?"

"The IRS released the unpublished version of the final catch up regulations which should be published in tomorrow's Federal Register ... 94 pages of reading enjoyment ... One interesting right up front is 'Applicability date: These regulations generally apply with respect to contributions in taxable years beginning after December 31, 2026. However, see Sections 1.401(k)-1(f)(5)(iii), 1.414(v)-1(i)(2), and 1.414(v)-2(e)(2) and the Applicability Dates section later in this preamble for additional details regarding applicability dates.' "