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September 3, 2026

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AllThingsForGood created a topic in Plan Document Amendments

Document Amendments: Need This Dumbed Down

"If I am putting a client into a brand new DC prototype Plan Document, what Amendments/Addendums should be in their Document package? ... I'm BRAND NEW to FTWilliam; leaving another software that I've used for almost 3 decades! When I print the Adoption Agreement in the FTWilliam system, the following are part of that:

  • the SECURE 2.0 Addendum 2026,
  • the SECURE 2.0 Addendum 2025, and
  • the SECURE/CARES/CAA Addendum.

It seems VERY redundant to send a client each of these 3 Addendums, but is that accurate? Or does just the '2026' version go with a Document package? Again, my brain may just be revolting against the transition tasks, and I have researched this but cannot find a clear (dumbed down!) answer."

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Basically created a topic in 401(k) Plans

Determine If SH Plan Annually

"I have never given a client the option, but a financial advisor is asking the question.... Can the plan sponsor decide year to year if their plan is a SH plan or not? and if so, how does this work? I know that to be a SH Match, for an existing plan they must decide prior to 1/1 of the new plan year.... but a plan can switch mid year to a SH plan by 12/31 if they add a 3% NEC SH contribution (after 12/31 if the NEC is 4%). Ok, say they did that.... that would be amending the plan which would mean the plan is now a SH NEC plan moving forward. To go back to a non-SH plan, well, another amendment switching the plan back? I'm getting dizzy just thinking of amending the plan each year. But.. is that how it is done? Or maybe I am totally off.... you can't do this year to year."

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MJ Hartman created a topic in Distributions and Loans, Other than QDROs

IRS Audit Wanting Updated 1099 for 2019

"Finishing an audit for plan year 2023. The auditors want a corrected 1099R completed for tax year 2019 (showing a taxable distribution of $75000 on behalf of a participant). Is this possible to complete? I can prepare the 2019 1099r form but cannot find a 1096 for 2019. does this qualify as an acceptable filing? Is the participant liable for tax payments on a distribution that was made 7 years ago? I'm not sure the IRS auditor/supervisor are aware of all tax liabilities since the auditor reminded me that participants unable to be located can have their full balances remitted via 100% withholding tax to the IRS."

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D Lewis created a topic in 401(k) Plans

5% Owner for RMD When Company Is Owned by a Trust

"We have a plan where the ownership is a trust. I believe this means the trustees of the trust are deemed to be the owners -- is that correct? So if an employee is a trustee of the the trust they are deemed to be a 5% owner, correct? Does it matter if there is more than one trustee? For instance if there are 4 are the all deemed to be 25% owners of the trust? Or are they all 100% -- or does it vary?"

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