"I'm newer to the MEP/PEP space, but I'm seeing this happening constantly -- wondered how common it is and what people normally do. An adopter moves from one PEO MEP (MEP A) to another (MEP B), effective 4/1/26. They had changed their PEO provider in November 2025 so had to make the switch. Their new PEO provider continued employee deferral withholding during the interim move from MEP A to MEP B. With the effective date of the adoption with MEP B not being until 4/1, these deferrals were sent MEP A to be deposited into employee accounts. MEP A would not accept these contributions, so the PEO has just been holding on to these contributions for months. My thought is that they would need to return the deferrals withheld between November and the effective date of the adoption into MEP B -- is there any other alternative?"

"Client received CP283 notice. I know we can still file under DFVC Program and request abatement, my question is, has anyone done that recently and does it still generally work?"

"A religious school that gets no funding from the diocese anymore is nonetheless still qualified as a QCCO. The school was established in the 1950s, and we suspect that it would have qualified prior to the adoption of the QCCO rules. The school has been told that they likely would not qualify as a QCCO if they were to seek it out now, although they are still listed as a church related entity in the master list of catholic organizations. The issue arose because the school wants to adopt a 457 plan. They are considering whether to 'reclassify' itself as a non-QCCO. ERISA and tax-qualification issues for their existing plan aside, have you seen a religious school undertake this process? Any thoughts? We realize that it can still adopt a 409A plan instead, but they would prefer that distributions be eligible for rollover treatment."