Looking for minimum coverage for a small, non-producing TPA. Who do you use?

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Two non-profit entities are merging. Employer A (the surviving entity) has a 401(k) plan and Employer B has a 403(b) plan. I'm curious what others' thoughts are as to whether they should terminate the 403(b) plan or adopt it and freeze it. I generally prefer the termination of a target's retirement plan prior to a merger/acquisition to reduce liability, administrative costs, etc. But do the complexities of terminating a 403(p) plan outweigh the potential benefits here? I believe assets are held in a group annuity contract, but there may be individual annuity contracts.

1. Can you 'convert' a plan from a single employer plan to a different structure like a MEP (and eventually, when/if made legal, a PEP) and move all of the assets over without making it a distributable event?
2. When a plan terminates, it creates a distributable event, I believe. Is there a way to convert these assets to a MEP -- say like a 'mass rollover'?
3. Finally, are there rules/regulations that prohibit starting a new plan within a short time window of terminating a current plan? If so, are there rules requiring 'grandfathering' of any specific provisions from the terminating plan?

We were recently contacted by a doctor, who received a CP214 Letter in February this year. His mother, who recently passed, took care of filing the 5500-EZ for him. Neither the doctor nor the accountant has been able to find copies of the prior filings. Would submitting the IRS Form 4506 be the only way to obtain a copy, or is there another option?

I took a loan from my 401k in 2017 but then left my job in December 2017. The last payment on the loan was posted in Jan 2018, this was a mistake on my former employer's part. Evidently they fund the 401k by a single monthly deposit which included all the employees contributions. They forgot to deduct my contribution amount & failed to inform the management company I was no longer employed there, so the payment was applied like normal. I didn't inform the management company of the error, I was hoping it would work out in my favor (my last day was actually Jan 2, 2018, but my former boss didn't want to file paperwork for me for 2018 so he paid me for my last day on my previous paycheck). Is Jan 2018 when the loan is considered 'deemed'? Is that last payment going to cause a problem because I was no longer employed there? Do I have until tax day 2019 to pay off the loan (based off 2017 tax reform)?

"Under the 2017 tax reform legislation, the 60-day deadline is extended to the participant's tax filing deadline for the tax year in which the offset occurs if the amount is treated as distributed from the participant's qualified 401(k) plan because either: [1] the plan was terminated, or [2] the participant failed to meet the loan repayment terms because of a separation from employment (if the plan provides that the accrued unpaid loan amount must be offset at this time)."

Also, I haven't received any form of communication regarding this loan since I left the former employer. Is that standard? I assumed I'd get a notice to warn of the loan defaulting or something informing me it had been deemed. I asked the management company if a letter had been sent. In the past they sent documents directly to my former employer, so I wondered if had gotten thrown away. They responded by forwarding me a copy of the promissory note without any further explanation. I'm a little perplexed over the lack of communication.

Have you ever had a situation in which you did not want to provide your usual service of electronic submission of a client's Form 5500 report because you believe the report your client instructs you to submit would include a false statement? (Your draft was accurate and correct, but your client tells you to change an answer to one that is false.) How did you handle the situation? Does a submitter have any responsibility for whether its client makes a truthful report?

If a DB plan has already been amended for PPA and is terminating now, prior to the end of the PPA restatement period, and before our document provider has the PPA documents available, does it still need to be restated for PPA?

A potential client has a DB plan in place with another TPA. They now want to start a 401k using my company as the TPA. My understanding is that the 401k plan will be for employees who were formerly contract (1099) employees and are now W-2 employees. None were ever in the DB plan. What are the testing issues involved? Other issues?

Sole proprietor wants to make contribution by contributing stock that he already owns to the retirement plan. Without regard to the wisdom of doing so, is it even permissible?

Notice of Intent to Terminate went out in December 2017 for a 1/31/18 plan termination date. Plan anniversary was March [1] Plan has been frozen since 2006. When the new rates went into effect March 1, the plan was more underfunded than the client anticipated. They took a couple months to figure out if they were going to go ahead with the plan termination. Now they want to move forward, but we're past the 180 days to file the PBGC 500. They really want to get it paid out by year-end but especially by PYE. Its not clear to me what the options are. I see where one can change the proposed termination date, but not more than 90 days. Have we missed that window too? Is there anything we can do at this point other than start over?

A sole proprietor and a partnership sponsor both a DB & a DC plan. The DB plan was frozen in 2017. One last contribution is being made to the DB plan. The entire DB contribution is being allocated to the sole proprietor and not the partnership.

• Is there any issue with that?
• If that's permissible, then is the entire DB used to reduce net income of the sole proprietor when I'm figuring the calculations for the DC plan?

I am aware of how the deduction limits work with combo plans, but I'm uneasy about allocating the entire DB contribution to the sole proprietor.