"I've worked on 401k plans for a while now, but only encountered mega Roth backdoor quite recently. I do understand that it has great tax saving for an individual but after digging deeper I read that ACP must be passed for the after tax voluntary contributions even if the plan is safe harbor and passed ADP and ACP for matching. Am I understanding this correctly? Also is there any way to bypass the testing for mega Roth backdoor after tax contributions?"

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"Safe harbor plan fails compensation ratio test for the match since bonuses are excluded. The plan document does not provide any type of correction method such as use total compensation. Does an 11(g) amendment correct this situation where compensation would be added back? I remember hearing in the past that if a safe harbor plan fails compensation tests it blows the safe harbor, unless the base document has a correction like the AQSC document does. This plan uses a pre-approved document but no correction language has been located. How do we proceed?"

"We are helping a takeover client with a DFVCP filing. The EFAST site only goes back to 2009 filings which makes sense. When going to the DFVCP payment web site, it lists Forms 5500 going back to 2004 as 'late filings found in EFAST at this time.' Question is how are pre 2009 Forms showing up on the DFVCP site as being on the EFAST site, but they are not actually displayed on the EFAST site. Maybe the client filed electronically, but it is not displayed on the EFAST site? In any case how do we amend those pre-2009 Forms and submit under DFVCP?"

"We have a small group of DB plans and work with an excellent actuary. Our plans are generally small but for one with several hundred participants. The sponsor wishes to start a new DB plan but would like it to look like their 401(k) -- online access to see balance, process distributions online, etc. Does anyone know if Ascensus has such a product. I did a search on them and was directed to their subsidiary Future Plan."