Two plans are sponsored by the same company. They want to merge them in order to make administration easier. One plan has a funding shortfall in the year before the merger but the other does not. So Rev. Proc. 2017?56 seems to say that the change in funding method would not qualify for automatic approval of a change in funding method. But, as of the merger date, the assets in the second plan are such that all shortfall amortizations in the first plan will be wiped, out and the plan after the merger will be more than 100% funded. The $10,000 user fee under Rev. Proc. 2017?4 seems excessive here because one company sponsors both plans and the only reason the change wouldn't qualify for automatic approval is a funding shortfall that's taken care by the merger. Comments?

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Plan A is merging into Plan B. Plan A allows for in-service distributions at age 59?1/2 from an deferral account. Plan B does not. What should be done to protect that benefit? An amendment to Plan B's document, or do I need to just include language in the merger resolution?

I'm curious to hear from everyone what kind of wellness programming/workshops you offer at your workplace. Chair massage, yoga, something else?

Has anyone ever heard of any enforcement of this provision by any agency? It's well established that no private cause of action exists to enforce it. I can't find that HHS has ever taken enforcement action to enforce it. In theory, being out of compliance triggers the excise tax under IRC 4980D, but I can't find that IRS has ever sought it, or any guidance from IRS. Has there been any consequence for failing to remove exclusions of certain types of provider from a self-insured health plans?

Back in November 2010, DOL issued proposed regs on target date funds. Were they ever finalized?

I have received an inquiry regarding drafting a QDRO for a health reimbursement account (HRA), which is covered by ERISA, but can't find any resources for this online. Has anyone come across this before?

ftwilliams volume submitter document. The adoption agreement says the Safe Harbor match is per payroll period. The employer wants us to calculate a true up. Is that legal?

This is a question for those who have or are working towards the CPC. How long did it for you to attain this designation (or a module if still working towards it) once you received the QPA and began studying for CPC? I'm trying to plan ahead. I plan to review the modules and take the exams at an average pace, whatever that means. For example, on the QKA/QPA, I averaged about one chapter per week and, with review, about 3 months between each exam. From a quick look at the CPC requirements, it looks like one has 4 required modules and 2 electives with online exams for each, and then a proctored exam at the end.

I'm looking for the rule as to what happens to a plan if a participant is allowed to take a nonqualified distribution and is unable to repay the money back. IRS corrective actions state the money needs to be restored but they don't say what happens if it can't be restored.

Calendar year plan -- we filed Form 5558 to extend the 5500 and the 5330 for a client. Now we find that the late deferrals were not for 2017 but instead were for 2015 and 2016. The client is asking to not file Form 5330 for 2017 because no late deposit of deferrals for that plan year. Are there consequences for extending Form 5330 and then not filing one?

Has anyone seen or does anyone have insight into why we haven't received an update from the IRS on hardship and loan relief to victims of Hurricane Florence, similar to other hurricanes such as Harvey and Matthew? From a quick Google search, it appears that the announcement was provided within a few days of the disaster in the past. The only update I can find is with respect to tax relief, but not hardships and loans. https://www.irs.gov/newsroom/help-for-victims-of-hurricane-florence