8955-SSA deceased records

[RSM103]

Good day,

 

I hope this is not a ridiculous question. Are deceased participants included in the 8955-SSA filing? The instructions are not clear to me. For example, if a participant dies while active, there is a benefit owed to the estate/beneficiary, but at this point is not owed to them, the SSN on the form. The same is true of those who termed in the past and were reported on an SSA, but died in the plan year. Their estate/beneficiary is paid out at this point, so should they be a D on the form with their SSN?

[ESOP Guy]

Their estate/beneficiary is paid out at this point, so should they be a D on the form with their SSN?

That to me is an obvious "Yes".  The point of this system is to send out letters to people to let them know they might be owed a benefit.  The point of a "D" is to stop that letter when the benefit is paid.  So if it has been paid do a "D" using the SSN that was used to set up the "A" for that benefit. 

If a person passes and there is a benefit due someone but you don't know who yet I guess I would report an "A" when needed.  If you know the beneficiary's SSN you could use that SSN. 

I don't think you are going to find clear guidance on these questions so being reasonable seems defendable. 

[My 2 cents]

I believe that the 8955-SSA is used EXCLUSIVELY to report participants and to document when previously reported participants have received what they were entitled to.  One NEVER reports a beneficiary on the form for any reason - it is only used to report participants.  The instructions make that clear by only referring to separated participants who meet one or more criteria. 

Further,  I don't think that it is ever necessary to report, as a "D", someone who had previously been reported as an "A" , whether or not there are death benefits payable to someone else, immediately or on a deferred basis, although putting them on there as a D is fairly easy.  For 8955-SSA purposes, the most you would ever have to do for someone previously reported would be to say that they have no further benefit entitlement (and even that may not be required). 

[My 2 cents]

Just now, My 2 cents said:

I believe that the 8955-SSA is used EXCLUSIVELY to report participants and to document when previously reported participants have received what they were entitled to.  One NEVER reports a beneficiary on the form for any reason - it is only used to report participants.  The instructions make that clear by only referring to separated participants who meet one or more criteria. 

Further,  I don't think that it is ever necessary to report, as a "D", someone who had previously been reported as an "A" , whether or not there are death benefits payable to someone else, immediately or on a deferred basis, although putting them on there as a D is fairly easy.  For 8955-SSA purposes, the most you would ever have to do for someone previously reported would be to say that they have no further benefit entitlement (and even that may not be required). 

TO clarify my second paragraph above - the first sentence is only with respect to participants who have died.  I meant to say that I don't think that people previously reported as A's who have died need to be reported as D's.