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Retroactively Decided Not to Make Safe Harbor Contributions for Your HCEs? We've Got a Fix (or Two) for That!

DWC 05/28/20
If you’ve been with us for a while you’ve heard us say a few things time and again.  First, the rules and regulatory agencies do not allow plans to disproportionately favor highly compensated employees (HCEs) relative to the non-HCEs.  Second, a plan sponsor must be very careful about how and when it implements or removes benefits from the plan.  ...
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When the Grass Isn't Greener with More Plans, There's a Fix for That!

DWC 03/13/20
In our last Correction of the Quarter, we looked at related companies setting up different types of plans for their respective employees and noted that this sort of structure isn’t “necessarily” a problem when it comes to 401(k) plans.  Well, as usual, the devil’s in the details, so we thought it was worth diving into what happens when this is a ...
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We Can't Find our Signed Plan Document, Now What?

DWC 03/10/20
Facts We have a new TPA for our 401(k) plan and they’ve asked for our current plan document that was effective January 1, 2017.  We know the document was signed back when it was prepared, but we can’t locate the signed copy.
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When More (Plans) Isn't Merrier: We've Got a Fix for That!

DWC 11/21/19
Stop us if you’ve heard this one before – a SEP, a SIMPLE, and a 401(k) walk into a bar…unfortunately, there’s not a great punch line at the end of this one.  Instead of some good laughs, this situation is a recipe for some issues in need of attention.  While it might be unusual for a single company to establish one of each, it is not nearly as ...
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Your Safe Harbor Actually Isn't? We've Got a Fix for That!

DWC 08/22/19
We’ve been through a few Corrections of the Quarter together now, and we appreciate you being along for the ride.  We feel this is pretty good stuff but, at the heart of it all, we’re pension geeks (no point in hiding it).  And while the rules and regulations get us going, we have a geeky passion for the opportunity to find creative solutions.
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Feeling Defeated in the Battle of Participant Loans? We've Got a Fix for That.

DWC 05/30/19
While not quite as ominous as a battle with the Night King, dealing with participant loans in retirement plans can be a daunting challenge for plan sponsors.  Because of Congress’ concerns about protecting plan assets from improper use by participants and plan sponsors alike, the loan rules are strict and unforgiving. 
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Are Missed Deferrals and Late Deferral Deposits the Same Thing?

DWC 05/14/19
Facts Our company sponsors a 401(k) plan.  One of our newer employees, Jane Smith, met the eligibility requirements and should have joined the plan on January 1st.  Due to an oversight, we forgot to enroll Jane in the plan until she asked about it a couple months later.  We assume that we need to make some sort of correction, and we’ve done some ...
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DWC News Update: The IRS Helps Those Who Help Themselves

DWC 04/22/19
The IRS did its part to make Friday, April 19th a really good Friday for those who sponsor qualified retirement plans.  After not making many friends when it jacked up the user fees for the Voluntary Correction Program (VCP) a year or so ago, the IRS has responded to industry requests (that DWC representatives helped draft) by now allowing plan ...
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Forfeiture Account Gathering Dust? We’ve got a fix for that!

DWC 02/28/19
With all the responsibilities that come with being a plan sponsor, not to mention a business owner, your plan’s forfeiture account probably doesn’t make it anywhere near the top of the priority list.  More than likely, forfeitures are allocated to the account automatically by your plan’s recordkeeper following a participant distribution.  Then, ...
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Forgot to (Timely) Execute a Document Restatement? There's a Fix for That!

DWC 12/20/18
You probably know that establishing a qualified retirement plan requires the formal adoption of a written, legal plan document.  And, if you’ve had a plan in place for any amount of time, you’ve most likely also been required to adopt a handful of mandatory amendments along the way. 
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The views expressed in this blog are those of the authors and do not necessarily represent the views of any other person or organization. All content is provided for informational purposes only and is not intended to be tax or legal advice.