Welcome, Shelby!
We’re so pleased to welcome Shelby Lashaway to the GJM family as a consulting and assurance administrative team member. Shelby joined us in early November. We hope you enjoy getting to know her a bit better in this fun Q&A.
Describe your role at GJM: Assist the consulting and assurance team, besides my role, I always have the goal to bring positivity and spread it like glitter!
Why did you choose the accounting industry? I wanted to experience something new, and truthfully, data is relaxing to me. When I interviewed with GJM I knew I would be doing something new and in turn there would be a learning curve. I had the ability to stay in a field I was more accustomed to, but as soon as I met the team here, I knew this was the place for me. I have never met a more welcoming group and instantly felt home!
What do you like best about accounting? The data and diversity of it all.
Are you from the Toledo area originally? If not, where are you from? I grew up just outside of Toledo, in Swanton.
What do you like about living in Northwest Ohio? I really love to be outdoors, and we have some really great Metroparks. There are also way less creatures in NW Ohio that could eat me while on a hike compared to other areas.
Where did you go to school? High School: Swanton. College: Ross College
Anything you’d like to share about past work/school history? I’ve transitioned from healthcare, aviation, tech, to now accounting. I’ve really enjoyed gaining new skills and meeting new people through these different industries.
Do you have any pets, hobbies, family you’d like to mention? I do! I’m a fur and feather mom, I have two Chihuahua mixes, three chickens, and a chinchilla.
How do you like to spend your free time? I absolutely love to cook, I’m definitely a foodie. If the weather is nice, I love to be outside and by the water any chance I can.
Favorite book? Favorite movie? Favorite book: More so favorite author, I love anything by Heather Graham. My favorite movie is Jurassic Park.
Welcome to the team, and to the GJM family, Shelby!
Established in 1996, Gilmore Jasion Mahler, LTD (GJM) is the largest public accounting firm in Northwest Ohio, with offices in Maumee and Findlay. Locally owned, GJM offers cloud-based accounting and provides comprehensive services including assurance, business advisory, tax, risk advisory, healthcare management and outsourced accounting. The firm’s professionals specialize in industries including construction & real estate, healthcare, manufacturing & distribution and utilities.
Are You Ready for Cycle 3 (Post-PPA) Retirement Plan Restatement?
Now’s the time to move forward with updating your employee retirement plan so that its in compliance with the latest IRS requirements.
Every six years the IRS mandates that retirement plans with pre-approved status update their plan document or restate… to incorporate any recent regulatory or legislative changes. In return, they receive a new “opinion letter” from the IRS.
We’re in the middle of a two-year restatement period for pre-approved defined contribution plans, which includes 401(k)s. The restatement period started August 1, 2020 and will close July 31, 2022. Since it is the third cycle of defined contribution plan restatement since the Pension Protection Act (PPA) of 2006, it’s also known as Cycle 3 Restatement.
What does it mean to do a plan restatement? In simple terms it is a complete rewrite of your retirement plan document. It will reflect those mandatory regulatory changes and include any voluntary changes you’ve made to your plan document since your last restatement.
Pre-approved document definition: A pre-approved plan document has fixed provisions and pre-selected choices that can be chosen by the plan sponsor. The pre-approved language has already been reviewed and approved by the IRS. Any employer adopting a pre-approved plan can be confident that the terms of the plan will satisfy IRS code requirements. An important terminology note: “prototype”/ “volume submitter” are terms you’re likely familiar with but are no longer recognized by the IRS. There are now two types of pre-approved plans: standardized and non-standardized. The chart below offers a helpful side-by-side comparison.
Standardized Pre-Approved Plan |
Non-standardized Pre-Approved Plan |
The format is composed of an adoption agreement and corresponding basic plan document. | The format is either composed of an adoption agreement and corresponding basic plan document or a single integrated plan document. |
The design is to satisfy the qualification requirements based solely on the plan terms. There are fewer design choices and elective provisions permitted. | Flexibility in design choices and elective provisions that go beyond the basic provisions. |
May rely on the issued opinion letter. | May rely on the issued opinion letter if non-standardized document is word-for-word. |
Modifications to the plan will result in becoming individually designed and losing reliance on the pre-approved status. | Minor modifications are permitted but the employer should file a Form 5307 by the restatement deadline. |
The number of allocation groups for Non-Highly Compensated Employees (NHCEs) is restricted based on the number of eligible Highly Compensated Employees (HCEs). | No restrictions on the number of allocation groups for NHCEs. **Preferred for cross-tested allocations** |
Cannot offer non-safe harbor hardships. | Cannot offer non-safe harbor hardships. |
Why do you need a plan restatement? As laws and regulations change, so must your plan document to remain in compliance. It must reflect new rules because of acts of Congress and new requirements from the IRS and US Department of Labor.
The IRS released its “Cumulative List of Changes” document in 2017, including new regulations in place since the prior restatement period that ended in April of 2016. But the cumulative list of changes happened before some other major changes included in the SECURE Act and the CARES Act.
SECURE Act and CARES Act changes won’t be part of Cycle 3 (or Post-PPA) restatement, but instead be incorporated separately through good faith amendments.
Why should you act now? The two-year plan restatement period is already half over. If you don’t do a plan restatement by the July 31, 2022 deadline, you’re subject to IRS penalties and can also jeopardize the plan’s tax status.
Some other important considerations:
- Any plans terminated and cashed out prior to the restatement period will only need to address the changes brought on by the SECURE Act and the CARES Act. They won’t need to do a full restatement.
- Plans you’re considering terminating, are inactive or frozen do need to go through the restatement process.
Our Specialization.
GJM Accounting Services Manager Molly Wolf specializes in employee benefit plans and assists many GJM clients with plan restatement. In many cases she works very closely with those responsible for managing their company retirement plan document. Other times the client prefers to be more hands off with the project. Each business must determine their level of comfort and what works best for them.
“There’s quite a bit involved in terms of evaluating a plan document, ensuring compliance, and avoiding any penalties,” says Wolf. “Quite often the retirement plan manager will step aside and let our team take the lead. That way they can rest assured they’ll stay in compliance.”
If you have yet to begin your plan restatement, Wolf says you probably don’t want to wait much longer. She says now’s the time to reach out to your service provider to be sure Cycle 3 (Post-PPA) restatement isn’t an afterthought, but a priority. GJM clients in need of a plan document restatement who haven’t begun this work already, are encouraged to reach out to their GJM team to discuss what’s needed.
Molly Wolf is an accounting services manager with over 15 years of experience specializing in employee benefit plans. The first 9 years of her career were spent as a dedicated employee benefit plan auditor. Her expertise also includes consulting for third party plan administration and benefit plan design, compliance testing, payroll integration and reconciliation. Since joining Gilmore Jasion Mahler in September of 2019, Molly continues to provide third party administration services, prepares related tax forms, consults on plan design, and prepares plan documents. She is a graduate of Bowling Green State University with a Bachelor of Science in business administration with accounting specialization
Established in 1996, Gilmore Jasion Mahler, LTD (GJM) is the largest public accounting firm in Northwest Ohio, with offices in Maumee and Findlay. Locally owned, GJM offers cloud-based accounting and provides comprehensive services including assurance, business advisory, tax, risk advisory, healthcare management and outsourced accounting. The firm’s professionals specialize in industries including construction & real estate, healthcare, manufacturing & distribution and utilities.
New Infrastructure Law Impacts Employee Retention Credit (ERC)
President Biden has signed into law the $1 trillion Infrastructure Investment and Jobs Act approved by the U.S. House of Representatives. The law will bring infrastructure investments across the country, including improved roads, railroad lines and other public transportation infrastructure.
The new law will also do away with what’s become an important benefit for businesses around the country still working to recover from the financial impact of the COVID-19 pandemic. The Infrastructure Investment and Jobs Act will end the Employee Retention Credit (ERC) early for most businesses. Expanded to certain employers as a result of the American Rescue Plan Act, the ERC had applied to the third and fourth quarters of 2021. Now the ERC will end with the third quarter of this year. In other words, any wages paid out after September 30 of this year won’t be eligible for the ERC.
If your business planned to take advantage of the ERC for the fourth quarter, be sure to be in touch with your GJM team so you can make the necessary adjustments in your business planning as we approach yearend.
We continue to watch developments in Washington, D.C. with the Build Back Better Act as lawmakers continue to work to come to an agreement. The proposed legislation addresses climate policy, social spending and would bring many tax policy changes. Lawmakers are hoping to pass something in the next couple of weeks.
Established in 1996, Gilmore Jasion Mahler, LTD (GJM) is the largest public accounting firm in Northwest Ohio, with offices in Maumee and Findlay. Locally owned, GJM offers cloud-based accounting and provides comprehensive services including assurance, business advisory, tax, risk advisory, healthcare management and outsourced accounting. The firm’s professionals specialize in industries including construction & real estate, healthcare, manufacturing & distribution and utilities.
