Glossary NUM. Aspen Pension Administrators, Inc Pan American Fwy NE, Suite B Albuquerque NM aspenpension.

Transcription

1 Aspen Pension Administrators, Inc Pan American Fwy NE, Suite B Albuquerque NM aspenpension.com Glossary NUM 401(a) A 401(a) is a retirement plan that employers set up and that meet the quali8ication requirements of the Internal Revenue Code (IRC), Section 401(a). Section 401(a) de8ines 401(a) quali8ied trusts and details the various quali8ication rules of a 401(a) plan. Each state has speci8ic laws governing 401(a) plans and a 401(a) plan must be either created or organized in the United States. Under a 401(a) plan, the employer determines the amount of money to be contributed each year (i.e. by the employee, the employer or both), vesting schedules and eligibility requirements that may be tied to job performance as a way to retain key employees. Under 401a, employers are allowed to create different 401a plans for different groups of employees, giving the employer 8lexibility in creating different incentive programs for speci8ic employee categories. However, there are speci8ic non- discriminatory requirements (i.e. detailed in IRC Section 401(a)5) that a 401(a) plan must adhere to. Funds from 401(a) plans may be distributed through lump- sum payments, rollovers, or annuity payments. 401(a) (9) Tax code section requiring minimum distributions for people who are who are at least 70 1/2 if they are terminated participants, active employees who are 5% owners, or traditional IRA owners. 401(k) Plan A de8ined contribution plan offered by a corporation to its employees, which allows employees to set aside tax- deferred income for retirement purposes, and in some cases employers will match their contribution dollar- for- dollar. Taking a distribution of the funds before a certain speci8ied age will trigger a penalty tax. The name 401(k) comes from the IRS section describing the program. 401(k) Pro5it Sharing Plan A type of pro8it sharing plan that includes an elective salary deferral provision. The employer typically has the ability to make a matching contribution that is tied to the elective salary deferral, as well as a pro8it sharing contribution that is allocated to all eligible participants. 402(g) limit Test to ensure that the total of each participant s elective deferrals has not exceeded the calendar year limit 403(b) Plan Also known as a tax- sheltered annuity (TSA) or a tax- deferred annuity (TDA), is an employer sponsored retirement savings plan for employees of not- for- pro8it organizations, such as colleges, hospitals, foundations and cultural institutions. 403(b) assets may also be invested in custodial accounts holding mutual funds. 457 Plan A tax- deferred retirement savings plan available to state and municipal employees and tax- exempt entities (for a "top hat" group). Like traditional 401(k) and 403(b) plans, the money contributed and any earnings that accumulate are not taxed until withdrawn. A Accrued Bene5it A bene8it that an employee has earned (or accrued) through participation in the plan. In a de8ined contribution plan, the participant s accrued bene8it is the balance in his or her individual account at a given time. In a de8ined bene8it plan, the accrued bene8it is determined as speci8ied by the plan.

2 AccuDraft Pension Retirement Plan document software Aspen utilizes to complete Form 5500, Extensions, SSA- 8955, etc. ACP Test Also known as the Actual Contribution Percentage Test. An anti- discrimination test that compares the amount of match contributed to highly compensated employees to the amount of match contributed to non- highly compensated employees. Actual Contribution Percentage Test An anti- discrimination test that compares the amount of match contributed to and/or after- tax contributions contributed by highly compensated employees to the amount of match contributed to non- highly compensated employees. Actual Deferral Percentage Test An anti- discrimination test that compares the amount of match contributed to highly compensated employees to the amount of match contributed to non- highly compensated employees. ADP Test Also known as the Actual Deferral Percentage Test. An anti- discrimination test that compares the amount deferred by highly compensated employees to the deferrals of non- highly compensated employees. Age-weighted Pro5it Sharing A type of pro8it sharing allocation where participant s age, or length of time until retirement, is factored into the allocation formula on an individual basis, so older participants receive a larger proportionate share of the contribution. ASC-Actuarial Systems Corporation Aspen utilizes ASC s Valuations and Compliance Testing Software ASPPA The American Society of Pension Professionals & Actuaries or ASPPA is a national organization for career retirement plan professionals. The membership consists of the many disciplines supporting retirement income management and bene8its policy. Audit A plan must have an audit for any year in which it has at least 100 participants (including employees who are eligible to, but do not, make contributions), or if it has assets of certain types, unless it purchases an enhanced ERISA bond. However, if the number of participants is between 80 and 120, and a Form 5500 was 8iled for the prior plan year, the plan sponsor may 8ile as the return/report in the same category ( large plan or small plan, with no audit) as was 8iled for the prior A plan has to be audited in the 8irst year they have over 100 Participants. In the second year, that number is raised to 120 Participants. If a company falls under 100 Participants, no audit is required. The audit is required by the IRS/DOL, to be performed by a CPA and is called a limited scope audit with the potential cost of $6,000 - $20,000. Automatic Rollover The transfer of vested account balances of terminated participants of $5,000 or less, to an IRA in their name, without their directive. B Basis Point A term used to express fees, expenses, or loads relating to investments. A basis point equals one one- hundredth of one percent, e.g.,. 01% equals 1 basis point. Bene5iciary A person designated by a participant or by the plan that may become entitled to a bene8it under the plan.

3 Blackout period A period of time when participants are not permitted to take loans, obtain distributions, or direct investments. A blackout period most commonly occurs during a conversion of plan's assets from one provider to another provider. Break in Service Generally, a 12- month computation period in which an employee is credited with no more than 500 hours of service. C Cafeteria Plan Also known as a Section 125 plan. A plan which allows participants to choose between cash and quali8ied bene8its e.g., health insurance, health 8lexible spending account to pay for or reimburse medical expenses, day care reimbursement account). The individual is giving up cash compensation to purchase welfare type bene8its. Cash or Deferred Arrangement A quali8ied pro8it sharing or stock bonus plan that gives a participant an option to take cash or to have the employer contribute the money to a quali8ied pro8it sharing plan as an employer contribution to the plan (i.e., an elective deferral ). These arrangements are often referred to as 401(k) plans. Cash-Out (Mandatory) Applies to plans that have a provision in their document that forces the distribution of a terminated participant. This can happen without the participant's consent, but is only allowed if the bene8it is $5,000 or less. Unless the participant elects otherwise, amounts greater than $1,000 must automatically be rolled over into an IRA. Distributions of $1,000 or less can be distributed directly to the participant. Distributions are subject to federal withholding tax, and may be subject to the 10% early withdrawal penalty if not rolled over. Catch-up Contributions A catch- up contribution allows people over age 50 to make additional contributions to their 401(k) and/or individual retirement accounts. The catch- up contribution provision was created by the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA), so that older individuals would be able to set aside enough savings for retirement. These contributions do not count toward annual addition limitations. Census A company s reporting of all Employees, active and termed that received W- 2 wages in the previous year. Cliff Vesting After a participant has earned three years of service in a de8ined contribution plan with cliff vesting, bene8its must be fully vested. CODA A quali8ied pro8it sharing or stock bonus plan that gives a participant an option to take cash or to have the employer contribute the money to a quali8ied pro8it sharing plan as an "employer" contribution to the plan (i.e., an "elective deferral"). These arrangements are often referred to as 401(k) plans." COLA An adjustment made to Social Security and supplemental security income in order to adjust bene8its to counteract the effects of in8lation. COLAs are generally equal to the percentage increase in the consumer price index for urban wage earners and clerical workers (CPI- W) for a speci8ic period. Comparability Older ownership in a company with younger workers, which gives younger employees 3-5 %, maximize owners to max out the employer contribution.

4 Compliance Services/Testing IRS Non- Discrimination Testing for Quali8ied Plans. Control Group Businesses that share common ownership. Depending on the percentage of ownership, companies under a controlled group (under common control) must be treated as one company for retirement plan purposes. There are three types of controlled groups: First, Parent- subsidiary, in which the parent organization own at least 80 percent of the subsidiary organization. For purposes of the annual addition limit, the 80- percent requirement is reduced to an amount more than 50- percent. Second, in a brother- sister controlled group, (1) the same 8ive or fewer persons own an aggregate of at least 80 percent of each business and (2) the individuals own more than 50 percent of each entity. Only identical ownership is considered. Third, a combined group, where a combination of parent- subsidiary control group and brother- sister control group exists. Contributions Monies contributed by the Employer and/or Employees to the Plan. Conversion The process of changing from one service provider to another. D Deferral Employee s contributions into the Plan. De5ined Bene5it Plan Such plans de8ine the bene8its to be received at retirement. The employer determines, within IRS limits, the level of bene8its, such as a 8ixed monthly payment or a certain percentage of compensation. Contributions are made annually to fund these bene8its based on the bene8it formula stated in the plan document. De5ined Contribution Plan Individual accounts are set up for participants and bene8its are based on the amounts credited to these accounts (through employer contributions and, if applicable, employee contributions) plus any investment earnings on the money in the account. DEFRA 84 De8icit Reduction Act of One portion of the Act was the Tax Reform Act of 1984 (TEFRA). TEFRA was the Tax Equity and Fiscal Responsibility Act of DFVCP The Delinquent Filer Voluntary Compliance Program is designed to encourage voluntary compliance with the annual reporting requirements under the Employee Retirement Income Security Act (ERISA). Gives delinquent plan administrators a way to avoid potentially higher civil penalty assessments by satisfying the program s requirements and voluntarily paying a reduced penalty amount. Direct Rollover A distribution to an employee made in the form of a direct trustee- to trustee transfer from a quali8ied retirement plan to an eligible retirement plan. DOL The Department of Labor administers the non- tax (regulatory and administrative) provisions of ERISA. The Department issues opinion letters and other pronouncements, and requires certain information forms to be 8iled.

5 E EACA An Eligible Automatic Contribution Arrangement enables employers to unilaterally enroll employees in their 401(k) plans at a speci8ied percentage of compensation and invest contributions in government approved default investment funds without fear of 8iduciary liability, and without being subject to state garnishment law restrictions. The arrangement can allow for the 90- day opt out provision. EBSA The Employee Bene8its Security Administration is an agency of the Department of Labor responsible for protecting the integrity of retirement plans, health plans and other employee bene8its. EGTRRA Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) Elective Contributions Also known as elective deferrals or 40(k) contributions. The amount of money the employee elects to contribute towards his/her 401 (k) plan. As quali8ied elective contributions are tax deferred for income tax purposes, the employer actually reduces the participant's income by the amount of the elective contribution. The accumulations and earnings in a 401(k) plan build on a tax- deferred basis as well. However, Roth 401(k) contributions are made with contributions that have been subjected to income tax. Eligibility The determination of when an employee becomes a participant in the plan. Employer Matching Contributions made by the Employer, matching the Employees based on a formula on the Employee s salary deferral contributions. Employer Non-Elective Contribution Pro8it sharing contributions, either discretionary or mandatory, made to the Plan by the Employer. Entry Date The date or dates speci8ied in the Adoption Agreement at which a participant can begins making and/or receiving a contribution. ERISA The Employee Retirement Income Security Act of 1974 is the basic labor law covering quali8ied plans and incorporates both the pertinent Internal Revenue Code provisions by reference and labor law provisions. ERISA Bond ERISA regulations require that all pension plans, including 401(k) plans, be insured by an "ERISA bond" which has a payout equal to 10% of plan assets, or $500,000 (maximum of $1,000,000), whichever is less. There is no difference between an ERISA bond, 8iduciary and 8idelity bonds. All three respond to claims involving dishonest acts on the part of asset investment advisors or the employer. The 8idelity, ERISA and 8iduciary bonds cover against losses due to a criminal act. ESOP An Employee Stock Ownership Plan is a retirement plan designed to invest primarily in the stock of the employer. Purchase of shares may be refunded by a loan, often by a bank, to the ESOP or the employer (which then makes a loan to the ESOP) to acquire shares. As the loan is repaid, shares are released for allocation to participants. ESOPs can align employees' interests with those of shareholders and can provide a tax- ef8icient way to transition ownership. Excess Contribution An amount, contributed by an HCE in excess of the amounts permitted by the ADP test for the plan year.

6 Excess Deferrals An amount contributed by a participant in excess of the limit on elective deferrals in Internal Revenue Code section 402(g) ($17,000 for 2012, indexed for in8lation). F Fidelity Bond ERISA regulations require that all pension plans, including 401(k) plans, be insured by an "ERISA bond" which has a payout equal to 10% of plan assets, or $500,000 (maximum of $1,000,000), whichever is less. There is no difference between an ERISA bond, 8iduciary and 8idelity bonds. All three respond to claims involving dishonest acts on the part of asset investment advisors or the employer. The 8idelity, ERISA and 8iduciary bonds cover against losses due to a criminal act. Fiduciary Any person (individual or corporation) who exercises discretionary authority or control over the management or disposition of plan assets. Forfeiture Portion of employer contribution account in which a participant is not vested and which is taken from the account and used to pay expenses, reduce future employer contributions or allocated to other participants when an employee separates from service with the employer. Form 5500 Annual return/report of quali8ied Plans that is required by DOL/IRS. Form 8955-SSA Annual registration statement identifying terminated Participants with deferred vested bene8its. G Graded Vesting Schedule A schedule used for vesting purposes, in which the vesting occurs over a period of two to 8ifteen years. A six year graded vesting schedule, a common vesting schedule, is where vesting starts with the second year of service at 20% and the participant fully vests at the sixth year of service. H Hardship Withdrawal A hardship withdrawal occurs when you take money out of your 401(k) or other quali8ied retirement savings plan to cover a pressing 8inancial need. You must qualify to withdraw by meeting the conditions your plan imposes in keeping with IRS guidelines. If you are younger than 59 1/2, you may have to pay a 10 percent penalty, plus income tax, on the amount you withdraw, and you may not be permitted to contribute to the plan again for a period of time. HCE-Highly Compensated Employee Also known as a Highly Compensated Employee. Anyone who is a 5% owner of a company or who received more than $115,000 in compensation in 2012 (indexed for in8lation).

7 HEART The Heroes Earnings Assistance and Relief Tax. Amended the Internal Revenue Code of 1986 to provide bene8its for military personnel, and for other purposes. I In-Service Distribution/Withdrawal A withdrawal of vested money from a quali8ied plan to an employee who is still actively employed. Integrated Pro5it Sharing Plan A plan that takes into account either bene8its or contributions made under Social Security. Investment Companies Companies who handle the investments of the Participants and/or Employers Contributions to Pension Plans. IRA Individual retirement accounts are self- directed investment accounts that provide the incentive of tax- deferred or tax- free earnings on assets in the account. If you earn income, or are married to someone who does, you can put up to $5,000 per year in an IRA in If you are 50 or over, you can invest an additional $1,000. IRA contributions may be deductible IRS This is an agency of the Treasury Department, headed by the Commissioner of Internal Revenue, charged with enforcing the tax laws. Included in IRS functions are issuances of interpretations of the tax law, auditing of tax returns, and making criminal investigations. J, K Key Employee A participant who, at any time during the plan year is (1) an of8icer who earns more than $160,000 as indexed, (2) a more- than- 5 percent owner of the employer, or (3) a more- than- 1 percent owner earning more than $160,000. L Life Annuity An annuity payable at least annually for the life of the participant, with no bene8its payable after the participants death. Loans IRS guidelines provide that the maximum loan available is the lesser of 50% of the Participant's vested account balance or $50, In the event that the Participant requesting the loan already has an outstanding loan balance, the amount of that outstanding loan will reduce the balance available for any subsequent loan. Lump Sum Distribution A one- time payout of assets in an account, typically a retirement savings account. When you retire or change jobs, you can take a lump- sum distribution as cash, or you can roll over the distribution into an individual retirement account (IRA).

8 M Mandatory Contributions Employee contributions that are required as a condition of participation in the plan, or as a condition for receiving bene8its or contributions under the plan. Matching Contributions Employer contributions that are made on account of elective contributions or employee contributions; also includes forfeitures that are allocated as matching contributions Multiple Employer Plan A single plan maintained by more than one unrelated employer. Mutual Fund A single account designed to create a portfolio of individual investments that may help to reduce the risk of owning individual investments. N New Comparability Formula A "New Comparability Formula" allows de8ined contribution plans to be tested for discrimination based on bene8its, just like a de8ined bene8it plan. An allocation formula averages projected bene8its for individuals or groups of participants, comparing what the contributions will grow to at retirement age. Aspen consults with this plan design for employers that want to focus contributions on speci8ic employees or groups. NIPA National Institute opf Pension Administrators. The National Institute of Pension Administrators (NIPA) is a national association representing the retirement and employee bene8it plan administration profession. It was founded with the idea of bringing together professional bene8it administrators and other interested parties to encourage greater dialogue, cooperation, and educational opportunities. NIPA's goal is to improve the quality and ef8iciency of plan administration. Non-Discrimination Testing Testing to determine whether a Plan discriminated in favor of Highly Compensated Employees or Key Employees. NHCE Employees who are not highly compensated. Generally, they are employees who earned less than $115,000 in 2012 (indexed for in8lation). See highly compensated employees. Non-elective contributions Employer contributions (other than matching contributions) with respect to which the employee may not elect to have the contributions paid to the employee in cash or other bene8its instead of being contributed to the plan. Non-Highly Compensated Employee Employees who are not highly compensated. Generally, they are employees who earned less than $115,000 in 2012 (indexed for in8lation). See highly compensated employees.

9 O, P Participants An eligible individual who has met the plan s eligibility requirements and can contribute to or receive employer contributions in an employer sponsored retirement plan. Pension/Retirement Plans 401(k) Plans, Pro8it Sharing Plans, Roth 401(k)/403(b) Plans, 457 Plans, 403(b) Plans, Prevailing Wage Plans and De8ined Bene8it Plans - including Stand Alones, Associations and Professional Employer Organizations (PEO) Plans types of pension/retirement Plans. Permitted Disparity Method of computing and allocating non- elective contributions under an employer sponsored plan, where the allocation method results in participants, with compensation above the integration level receiving a higher percentage of contribution. Plan Administrator The individual at your current/former place of employment that handles the day- to- day operation of your retirement Plan. Plan Document The written document setting forth the terms of the plan, including the eligibility and vesting requirements, how bene8its are determined, and when bene8its may be distributed. Plan Sponsor An employer who offers the plan to employees. The sponsor is responsible for choosing the plan, the plan provider and the plan administrator, and for deciding which investments will be offered through the plan. Pension Plan Administrator Aspen Pension Administrators, Inc. is the third party service provider employed by our clients for the purpose of consultation and administration. PPA 2006 The Pension Protection Act. Legislation signed into law on August , for which the primary goal was to protect and enhance the retirement savings and pension provisions. Q QACA A Quali8ied Automatic Contribution Arrangement is an automatic contribution arrangement must provide a speci8ied schedule of automatic contributions, an employer contribution, and notices to participants describing the plan provisions. The QACA satis8ies the Safe Harbor rules and is deemed to pass most non- discrimination tests. QDIA Quali8ied Default Investment Alternative. The Pension Protection Act of 2006 (PPA) includes a provision which insulates plan 8iduciaries from liability associated with an approved default investment option. QDRO A Quali8ied Domestic Relations Order is a judgment, decree or order that creates or recognizes an alternate payee's (such as former spouse, child, etc.) right to receive all or a portion of a participant's retirement plan bene8its. QKA The Quali8ied 401(k) Administrator credential was created by ASPPA for retirement plan professionals who work primarily with 401 (k) plans.

10 QMAC Quali8ied Matching Contributions are matching contributions that are 100% vested at all times and that are subject to the same distribution restrictions as elective contributions. QNEC Quali8ied Non elective Contributions are a non- elective contributions that are 100% vested at all times and that are subject to the same restrictions on distributions and elective contributions. QPA The Quali8ied Pension Administrator (QPA) credential was created by ASPPA to recognize professionals who are quali8ied to perform the technical and administrative functions of quali8ied plan administration. QPA's assist employers, actuaries, and consultants in performing functions such as determination of eligibility bene8its, computation of bene8its, plan recordkeeping, trust accounting and disclosure, and compliance requirements. Quali5ied Plan Design Pension Plans with provisions that satisfy the various IRS and ERISA code sections. R Recordkeepers Typically are Investment Companies who maintain the Employers and or Employees/ Participants contribution records for each Plan. Rollover A distribution in which assets move from one tax- deferred or tax- free investment to another. Roth 401(k) A 401(k) feature that allows employees to make elective contributions on an after- tax basis. Quali8ied distributions from these plans, including both the Roth contributions and their associated earnings, are distributed tax- free. S Safe Harbor Plan 401(k) or 403(b) plans in which the employer makes contributions according to a safe- harbor formula, so that the plan automatically passes the ADP and/or ACP nondiscrimination testing, and top heavy testing. Salary Deferral Contributions Each Employee/Participant's actual money put (deferred) into the Plan. Self Directed Brokerage Account Allows you to select from thousands of publicly traded mutual funds in addition to your Plans core investment options. SEP IRA Simpli8ied employee pension. A de8ined contribution plan in which employers make contributions to individual employee accounts. Generally, employees do not contribute to the plan; there are some grandfathered SAR- SEPs. SIMPLE 401(k) Plan Savings Incentive Match Plan for Employees. A type of de8ined contribution plan for employers with 100 or fewer employees in which the employer matches 100% of employee deferrals up to 3% of compensation or provides non- elective contributions up to 2% of compensation. These contributions are immediately and 100% vested, and they are the only employer contribution to the plan. SIMPLE plans may be structured as individual retirement accounts (IRAs) or as 401(k) plans. Regular 401(k) plans allow larger contributions than do SIMPLE IRAs and SIMPLE 401(k)s, and SIMPLE 401(k)s can allow loans, which SIMPLE IRAs cannot.

11 SIMPLE IRA Plan Savings Incentive Match Plan for Employees. A type of de8ined contribution plan for employers with 100 or fewer employees in which the employer matches 100% of employee deferrals up to 3% of compensation or provides non- elective contributions up to 2% of compensation. These contributions are immediately and 100% vested, and they are the only employer contribution to the plan. SIMPLE plans may be structured as individual retirement accounts (IRAs) or as 401(k) plans. Sponsoring Employer Employer who establishes and maintains a quali8ied pension plan. Summary of Material Modi5ication (SMM) A summary of amendments and changes made to the plan that is distributed to participants in the interim period until a new SPD is distributed. Summary Plan Description (SPD) A document describing the features of an employer- sponsored plan. The primary purpose of the SPD is to disclose the features of the plan to current and potential plan participants. ERISA requires that certain information be contained in the SPD, including participant rights under ERISA, claims procedures and funding arrangements. Aspen creates and distributes the SPD to each client at the time of initial set- up of their Plan. T Tax-Sheltered Annuity Plan Also known as a 403(b) plan or a tax- deferred annuity (TDA), is an employer sponsored retirement savings plan for employees of not- for- pro8it organizations, such as colleges, hospitals, foundations and cultural institutions. 403(b) assets may also be invested in custodial accounts holding mutual funds. Top Heavy Minimum The top- heavy minimum bene8it in a de8ined bene8it plan must not be less than the employee s average compensation multiplied by the lesser of 2% times the number of years of service, or 20%. Top Heavy Plan A plan in which 60% of account balances (both vested and non- vested) are held by certain highly compensated employees. Top Paid Group Employees who are among the highest paid 20% of all the employees of the employer. See Highly Compensated Employee. TPA-Third Party Administrator/Third Party Administration A Plan Administrator who is unrelated to the sponsoring Employer of the Quali8ied Plan. Trustee The individual, group of individuals, bank, or trust company having 8iduciary responsibility for holding plan assets. U, V Valuation Date Refers to a point in time in which an asset is assigned a dollar value. It is a term often used in reference to valuation of assets to be distributed upon occurrence of an event, or a periodic determination of worth for reporting purposes. Also known as balancing the books.

12 Vesting Schedule The structure for determining participants' right to company contributions that have accrued in their individual accounts. In a plan with immediate vesting, company contributions are fully vested as soon as they are deposited to a participant's account. Cliff vesting provides that company contributions will be fully vested only after a speci8ic amount of time, and that employees who leave before this happens will not be entitled to any of the company contributions (with certain exceptions for death, disability or retirement). In plans with graded vesting, vesting occurs in speci8ied increments. Volume Submitter Plan A volume submitter plan is a type of individually- designed plan. All volume submitter "specimen" plans are approved through the IRS Key District Of8ice in Cincinnati. A volume submitter plan can be structured like a prototype (with a basic plan document and an adoption agreement) or as a self- contained single document that only re8lects the provisions selected by an adopting employer. The IRS permits more 8lexibility in volume submitter plans. An employer may modify the terms of the pre- approved volume submitter plan. Voluntary Correction Program (VCP) A plan sponsor can correct errors in its retirement plan by using the IRS's Voluntary Correction Program (VCP), in which the plan sponsor submits an application to the IRS to correct the error, pays a fee, and negotiates IRS approval of the correction. W, X, Y YTD Year to Date Z February 28, 2012