"We have a group that inadvertently formed a MEWA a few years ago and never filed the Form M1. They are debating to file them late now. Has anyone had any experience in doing this? Has anyone heard of group paying the very high penalty for not filing: $1992 per day late?"

"Disagreement in our office about when the CARES Act and SECURE Act amendments must be done. One person saying 12/31/25 and another saying 12/31/26."

"In a stock acquisition, often a buyer requires target/seller to terminate target's 401k plan pre-closing. Can a buyer instead choose to terminate its own (buyer's) plan pre-closing and join the target's plan post-closing? Or does this run afoul of the successor employer / alternative defined contribution plan rules?"

"A dentist friend has his and his employees' money all invested in group annuity contracts. Although he and his employees get annual statements from the TPA, he is not able to check the balances more frequently. He would like to have a more typical 401(k)/profit-sharing plan where he could invest money in mutual funds. Here are some questions I have: [1] Because there are surrender charges, if he were to surrender those policies and move the funds to a new recordkeeper, would that be considered violating the ERISA fiduciary rules because the participants would take large losses? [2] Assuming that the answer to Q1 is 'No', meaning that he is allowed to surrender his policies and does not violate ERISA, how does the new TPA calculate the funds allocated to the owner vs. the rest of his employees? Given that the employees have been receiving the annual statements, there must be a way or a method that the TPA follows to allocate these funds on a participant-level."