PBGC audit briefly resurrects plan

[SheilaD]

On one of the many PBGC audit's that we've had over the last year - one of my clients is being forced to pay some additional interest to certain participants due to the date they were paid out versus the date their PVAB was calculated. We did a final 5500 for 2010. Now the client must pay $x to around 10 participants and do 1099's. I don't know whether this makes it necessary for us to file a new final 5500 for 2012. I am sure that if we do so, we'll end up with inquiries about where 2011 is. Has anyone had this situation and do you know what we should do?

thanks for any thoughts.

S

[david rigby]

1099-R?

If being paid under plan EIN, and using a 1099-R, that looks a lot like a plan distribution to me. Presumably, this extra payment will be rollable?

[SheilaD]

1099-R?

If being paid under plan EIN, and using a 1099-R, that looks a lot like a plan distribution to me. Presumably, this extra payment will be rollable?

Yes a 1099R using plan EIN and it will be rollable. That's why I'm concerned that I might need to do a 5500.

Or to be more frank -- looking for an excuse to not do a 5500.

[Bird]

I can't give you an excuse but I would be comfortable "forgetting" that it might be required. Hard to do that with a straight face since you posted the message but yeah, it would be opening Pandora's box on new queries.