"An employee's date of entry was 1/1/26, but he was not informed that he could start deferring at that time. The employee has yet to complain to the employer about this -- it was the employer who caught this error. The employee will be permitted to begin deferring with the first payroll period ending after 4/1/26. This should suffice for reducing the QNEC for the MDO to 0%. The plan does not have any autoenrollment features. Some sources say an MDO notice is still needed, some say it is not. I'm leaning more to the 'not needed' side, especially since the employee has not brought up the discrepancy -- is this the way to go?"

"I have a PBGC covered plan where the owner took an impermissible withdrawal of $250k from the plan in June 2025. To correct, he returned the funds to the plan in February 2026 but with no earnings adjustment. Are earnings required? He wants to self correct and include a memo in the plan's files."

"403b Plan D was at Recordkeeper R about ten years ago. They had about 20 participants with defaulted loans. Recordkeeper R is an insurance company, so they treat the loans as loans from the vendor. The plan converted to a new recordkeeper, but R said that they have to maintain the defaulted loans. We came into the picture a couple of years later and weren't successful at getting them to change their mind. Now participants who have these old defaulted loans are looking to take a new loan -- they call the new recordkeeper who of course has no information on these old defaulted loans and are told that they can certainly take a loan. Then all sorts of headaches ensue.

'Let's say that repaying the defaulted loans with accrued interest is not an option -- almost all of them are for workers just above minimum wage. They're basically taking a loan to get access to the profit sharing while still employed. The plan currently doesn't allow age 59.5 ISW, but most are under that age anyway. Can we amend the plan to allow for a second loan ONLY to participants who have a defaulted loan at Recordkeeper R? There are no HCEs in that situation, so from a purely mathematical standpoint, it should be fine. Note that this is not what I'm suggesting they do. I'm just looking for options."