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QRDO Quandary


ldr
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Glad to hear this is being resolved to everyone's satisfaction. I understand that the account owner was pushing for the disbursement, but would like to point out that for the ex to get her share of the funds from an account belonging to her husband, the normal process calls for her lawyer to get a QDRO submitted in a timely manner.  Failure on the part of the lawyer to do that (timely) may be malpractice. (I am not suggesting it is here, but sharing as an FYI.) 

There was a case out of NY where the lawyer for the spouse dallied on getting the QDRO done correctly (he had tried once and was told his document did not satisfy the Plan's standards for a QDRO).  Meanwhile, a few years went by, and the economy tanked; the husband's retirement account lost just under 40% of its value from the date on the Court order.  The wife's attorney had a successful malpractice claim brought against him for failure to act diligently and secure the funds with a QDRO in a timely manner. Attorneys in every jurisdiction in the US have a duty under their respective Rules of Professional Conduct to be diligent, and waiting around when the economy (or other factors, including a spouse who actually intends to abscond with the funds) can negatively impact the value of the awarded property, is a failure of the standard of care he/she owes the client.   

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I would be pleased with a happy outcome.

If your plans are going to take action, particularly restricting accounts, the written QDRO procedures must spell out the circumstances and the procedure.   And that is not the best policy or protection for the plan.  It is a suggestion of the first published federal court decision on the subject as an approach that might pass muster. That court imposed liability on the plan for restriction based on less than receipt of a domestic relations order.  The Department of Labor doesn’t quite have a grip on the law in this area, but you should take some comfort in its position that the plan should act on suggestion.

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@fmsinc, your reply is fascinating.  I had no idea so much plotting and scheming was going on.  If I could please ask a practical question:  I can see the appeal of amending the marital settlement agreement the way you suggested in order to avoid the 10% penalty tax.  However, what would compel the ex-wife to give the participant his share of the funds, once the distribution was complete?  People who are on somewhat amicable terms and can trust each other to honor agreements might be able to work this out, but what if they aren't?  The agreement might stipulate that she is supposed to split the proceeds 50/50 with him, but when she receives the funds, what if she doesn't comply?  I don't think the participant is going to want to take that chance.  He's also in a hurry for a fast resolution and I don't know that he can wait on an amendment of the agreement.  It is a great strategy to know about, though.

@BVoss, I think a lot of the problem lies in the fact that possibly there wasn't an attorney involved at all.  In one conversation, the participant made the statement that his ex had "done it all, paid the lawyer, whatever"  but on the other hand, the HR lady said the ex-wife had gotten a boiler plate divorce document and done all the work herself to save money.  I realize that it was up to her and/or her attorney to have done a QDRO correctly.  At this point, the participant and the ex seem to be working together to try to come up with a DRO as cheaply as possible (or for free) and as far as we know now, they are trying to get it done with what we provided to them.  Neither of them seems to be able or willing to hire competent legal advisers.  That really is the source of my problem to begin with.  I have only ever worked on cases where I was presented with a DRO or a QDRO.  With a DRO, my job was to determine whether all the ingredients were in the document.  Lately, I have been presented with QDROs where the attorney, without any input from us, has run the document by the judge and he has declared it to be a QDRO without the review process.  If something is missing, I have to get the attorney to make changes to the document and take it back to court.  I did have a case once, earlier this year, in which the parties to a divorce were truly abysmally poor and had to get the job done with no money.  That's when our ERISA attorney gave us a DRO boiler plate to share in hard luck cases.  That couple managed to get someone to complete the form, the judge blessed it into QDRO status, and we were able to proceed.  This particular case started out as "there is no DRO, there is no QDRO, there isn't going to be a DRO or a QDRO, the participant isn't going to pay a lawyer to draw one up and neither is the ex."  We just hadn't had that happen before, and yet we had to deal with an anxious HR department and a participant who wants money within 2 weeks so he can move.  Anyway, it all seems to be working out now.  He will either get the DRO approved, or he will take a distribution of all of the account and pay all of the taxes, and either way, he has some degree of control over what happens, and we now know a lot more than we did before.

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Here is something you need to know about an important issue that is inadequately covered by your playbook.   The divorce proceeding, and all that comes out of it, including the terms of the settlement as reflected in the domestic relations order to be submitted to the plan., is personal to the plaintiff.  Plan, its fiduciaries, and its service providers, are in line for a heap of trouble if they intervene or advise about personal matters, especially personal tax matters.  The contents of the Tax Notice and what might be in the SPD are as far as the plan should go with respect to advising about tax consequences and strategies.  I know you don't like to receive anything I have to say,.  If your interest in fmsinc's post is academic, OK, but if you are thinking of passing along any advice, you are going way out on thin ice unless you are expressly engaged to provide services to participants'/employees.

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Our Benefit Election forms have a section called  COURT ORDERS where one of two choices   ("are"  or  "are not") needs to be checked:

     [  ]   I hereby certify that my benefits   [are / are not]  subject to a court order dividing benefits as a result of a dissolution of marriage.

                     (These are actually 2 separate lines on the Election Form)

 

Assuming the participant  checked the   "are"   box,  wouldn't that stop you from further processing of the benefit request?  ....... i.e.  go back to the participant to say   "Get a QDRO, and send it to the Plan."    In absence of getting the QDRO subsequently, I leave it to the attorneys to answer.

 

....   Jeff

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A number of the posts in this thread seem to focus on the question of whether or not  the amount awarded from a defined contribution plan will be subject to gains, losses and investment experience from the "valuation date" to the date of transfer to the Alternate Payee (via tax free rollover or taxable distribution, as the case may be) or the segregation of the Alternate Payee's benefits by the Plan before such transfer.  

Here is a Memo I prepared for my colleagues here in Maryland.  

Gains, Losses, Ownership Interest and Constructive Trust.pdf

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Idr -

the information you provided regarding the divorce decree and the reference to the retirement plan sounds like it was in the boilerplate document she completed herself.  What it does not state is the account number, the value of the account as of a certain date, if there was a loan on any of the funds, etc. After all, there is volatility in the stock market.- so, upon receipt of a proper QDRO or divorce decree, the funds should be sold as of a certain date and the value frozen to -protect the assets for both parties sake. In addition, the one paragraph puts the responsibility on the Respondent to direct the Plan Administrator to divide the funds equally.  Why would the responsibility of dividing the account be placed upon the Respondent?  That is just crazy.  This isn't how a real QDRO is written. A real QDRO is sent to the TPA or Plan Administrator directly and if it is handed over instead,  it  must be signed by a Judge and entered into the court system as a valid document. This does not sound like a "valid" document and would not  hold up in any court of law.   If the employee is married, the 401k beneficiary is the wife and if a distribution is made, they wife would have to sign off on it.- but how do you know if it's the wife's signature?    Since the Respondent has terminated employment and you don't have a valid QDRO signed by a Judge- he probably could direct you to rollover 100% of the funds into an another account  and be done with it.  Without a valid QDRO signed by a Judge - there is no legal document.  This is just my 2 cents.  


The lawyer made a one paragraph passing reference to the participant's retirement account in the Marital Settlement agreement.  "Respondent has a retirement plan with XX Company.  Upon distribution of the funds in this plan,  Respondent will direct the Plan Administrator to divide the funds equally between the Respondent and the Petitioner, that being 50% to each party, however distributed."  

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Good morning to all,

@QDROphile, I am not going to get into a discussion about how to save the extra 10% on $30,000 with the participant.  It is an interesting "dodge" and could be useful in the future but it was hard enough to get to the point we are at now without muddying the waters any further.

@JeffHartman, we are using distribution forms of John Hancock, so we can't edit a form in this particular case and add the language you are suggesting, but I like the idea.

@fmsinc, the QDRO boilerplate we furnished to the participant is silent on the subject of earnings.  It would appear from the way it is worded that if they agree on the division date as being the date the divorce papers were signed, then she will get 50% of whatever was in the account on that day.  But thank you for the memo, which I will read at lunch - it's a little long and duty calls.

@My2Cents, We realize that the little paragraph didn't constitute anything remotely resembling a DRO.  We were led to believe at first that there would not and could not be a DRO or QDRO forthcoming.  That changed yesterday when our participant decided to try to develop his own DRO using a boilerplate document from our ERISA attorney.  It will have all of the ingredients you mentioned.  If he can get a judge to bless it, we can split the account.  If he can't, he can indeed direct us to distribute ALL of his account in any manner he dictates.  That is what came of all of this discussion - we now understand that we can't hold his funds up if he wants a full distribution, he understands that if he doesn't get a QDRO he's going to pay taxes on the whole sum, and now we will see what happens.

Thank you, all of you.

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17 hours ago, QDROphile said:

  If your interest in fmsinc's post is academic, OK, but if you are thinking of passing along any advice, you are going way out on thin ice unless you are expressly engaged to provide services to participants'/employees.

This is one of the more important takeaways from this thread.  Stay within the terms of your engagement, period.

 

 

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Idr - this has been one of the most informative and, frankly, the most fascinating thread I've seen on this forum (though I am relatively new). I really do hope you choose to stay in the forum and not leave it as you stated you were thinking of doing early on. So many questioners might not have hung in there when initially feeling quite disappointed. I seldom see the original questioner continue to be so engaged in the process, thus making this thread a great resource for others to find in their future electronic searches for information about the QDRO process and the twists and turns inherent with the topic. Bravo to you (and to all those who contributed).

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Two points, both drawn from the DOL QDRO handbook:

1.The court order between the parties is a DRO that should be qualified by the plan.  If the participant is eligible for a distribution, 1/2 goes to participant, 1/2 to spouse, alternate payee. I am assuming the court did not enter a divorce decree without a property settlement, so assume that the property settlement dividing the account was incorporated into the divorce decree. I am also assuming that the participant had notice of all of the proceedings, and must have signed the settlement agreement?  

2. There does not need to be a separate order to the plan to pay -- the plan is required to "honor" the division of property by the state court order.  Long ago, and in a far away place - California - plan administrators refused to give account information to prospective alternate payees, and refused to honor division of ERISA benefits pursuant to state court DROs. In response, California enacted a law requiring automatic joinder of ERISA- covered retirement plans in state domestic relations matters in order to enforce information disclosure and property divisions in DROs. The DOL spent a number of years, unsuccessfully, trying to convince california courts that the joinder law was preempted by ERISA.  Following that  - DOL advice to plan administrators when receiving any state court order was to politely reply that the plan would comply with the disclosure or distribution (if the order complied with ERISA and the plan terms) based on the plan administrator's duties under federal law, not state law. 

Why would any plan administrator voluntarily submit itself to state court jurisdiction?  What if the state court ordered  the plan  pay in a form of distribution (like lump sum) not provided for by the terms of the plan?  Or ordered the plan to pay the parties' attorney's fees? Or ordered the plan to pay to an alternate payee not entitled to a distribution from the plan (like the third spouse when the second spouse already had a valid QDRO on the account?).  If a DRO contained any of these provisions,  the plan administrator should reject the DRO, and the remedy, after any administrative appeal that might be provided by the plan's QDRO procedures, would be for the putative alternate payee is go to federal district court. 

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@Doc Ument and also ESOP Guy from an earlier post:  Thank you very much for your encouragement.  I really do appreciate it.  And I know I need to grow a "thicker skin" but at this late stage of life it probably won't happen. :)

@Tigerket:  I think you are getting at a part of my question that was never resolved clearly in my mind.  To be clear:  We do have a QDRO procedures policy that came with our document system and we follow it when we get a DRO or a QDRO that we can recognize as a DRO or QDRO.  We had only ever seen a separate document, clearly labeled as a DRO or QDRO, that generally contains most of the ingredients in the recipe and mostly never asked for anything the plan doesn't allow.  All we have ever had to do is decide whether a DRO in draft form was complete, or a QDRO processed without us actually had been done right.

The little 3 sentence paragraph I quoted from this case is a part of a 3 page Marital Settlement Agreement that covers children, spousal support, property (just a couple of cars), child support, insurance, income tax, "retirement", liabilities, debts and fees.  They both signed it.

We were struggling with and still struggle with our obligations given that at first, we were told that no DRO and no QDRO would be forthcoming.  If all we would ever get was that one little paragraph, what were our obligations and what were the obligations of our client?  Plus, we didn't realize that until we got a proper QDRO, we would be obligated to honor the request of the participant if he wants to withdraw his entire account.

Now if I understand you correctly, you are saying that the little 3 sentence paragraph was a DRO, in and of itself, and that's what I was afraid of and needed to have clarified.  We can't afford to just blithely ignore this document and say that until we get a proper QDRO, we have no obligation to do anything.  

We are back to this:  If we as a TPA know that a former spouse has a right to a portion of a participant's account, we cannot ignore it.  Anything we get in the future, even if it is just one paragraph, will be suspected of being a DRO, and we will follow the procedures until it becomes a QDRO.  And apparently, if we never get the QDRO, then the participant can withdraw his entire account if he has an event that allows for distributions, and the fight is then between him and the ex-spouse and we have no further liability.  

We have not yet heard back from the participant as to what he wishes to do or whether he was successful in getting his home-made QDRO approved or in line to be reviewed.  I will update the column when we find out.

 

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While it is my understanding a martial settle agreement can in theory be a DRO and a QDRO.  What the people I know that know this subject well tell me is as a practical matter they almost never have all the needed characteristics.  

 

Based on the original description I don't see a QDRO. 

It has always been my understanding that DROs should be rejected for what seem like even minor technical issues.  For example in the ESOP world we see DROs come in that call the plan, "XYZ Corp Employee Stock Option Plan".  We will always recommend the client reject the DRO and make them get the right name "Ownership".  

So unless what was sent to you have all the the needed requirements I stand by the advice given by most of the people in this thread. 

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@ESOP Guy, we are in agreement but we are just saying the same thing two different ways.  We thought a Marital Settlement Agreement was a separate thing, not a DRO, not a QDRO, and not capable of being considered either one, and not capable of containing either one, because we never saw it done this way before.  We expected a separate document, a 4-5 page thing clearly labeled DRO or QDRO.  When we were told we would never get that, we didn't know how to treat what we did get.

I totally agree with you that so far, nobody has presented us with anything like a real QDRO.  But what Tigerket was saying is that the one three-sentence paragraph in the Marital Settlement Agreement was a DRO, however incomplete it may have been.  That's what we did not know, along with not knowing that the participant has a right to take his entire account out right now, as a terminated participant, regardless of what is in the Marital Settlement Agreement.  

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ldr - Some of your instincts were correct, despite the doubt leveled at you by QDROphile.   Obviously from these posts,  it seems like lots of plans still expect to get some additional order covering the plan benefit,  or requiring a separate order directed to the plan from the judge, for the plan's "protection," but it is not necessary, and causes, as here, extra expense for the parties. Take a look at  DOL Handbook  Q1-2 and Q1-7. The only plan administrator who may ask for a court order directing it to pay is the PBGC - and that is because when an AP seeks a division of a pension benefit from a plan administered by PBGC, the claim is for a federal benefit, not just asking a private plan to honor a state court division of property. 

I am sure I will get a fight back  since QDRPhile thinks the DOL has been wrong too.  And I don't mean to fault plan administrators in general -- (altho courts do when the PA is too hypertechnical in qualifying DROS) - there is sufficient ambiguity in the domestic relations laws, and in ERISA, its case law, and agency guidance to be confusing.  Courts generally, if it comes to that, are deferential to the DOL guidance, even sub-regulatory guidance, so that is a safe bet. 

Your instincts were also correct on what protective measures a plan should take.  The DOL Handbook is instructive there too. First Q 2-1 - on disclosure - altho the types of parties who are prospective APs is small, and some are entitled to benefit statements anyway (spouse), the plan may request proof that a request for information is in connection with a domestic relations proceeding,  but then the plan must give the prospective AP any and all information necessary to draft a DRO.

 The question of how long a plan should protect benefits in a disputed situation is harder to answer, as you will see from the Handbook Qs 2-11-13.   And there are variations.  Courts don't generally fault a plan if the plan has absolutely no knowledge of a DRO (or perhaps even of a spouse), and makes a distribution to the participant.  Plans aren't likely to be faulted by the courts for not paying out when a dispute is known, but there is much confusion about the "18 month period" for waiting when benefits are already payable.  This waiting period does not answer all situations.  For instance,  most plans experience, at some point, receiving inquiries, and even draft DROs, or other evidence, but then not hearing back from the AP indefinitely.  Then the participant applies for a distribution of the entire account. Things happen - the AP decides to accept the house, the boat, and the dog instead of a share of the pension.  Or the parties reconcile (it happens!).  A plan can protect itself, by writing to all of the parties, and their attorneys, stating that the plan will honor the participant's distribution request unless it receives notice that there is still a dispute over the plan benefit.  

I will now step down off of my soap box.

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1 hour ago, ldr said:

@Doc Ument and also ESOP Guy from an earlier post:  Thank you very much for your encouragement.  I really do appreciate it.  And I know I need to grow a "thicker skin" but at this late stage of life it probably won't happen. :)

@Tigerket:  I think you are getting at a part of my question that was never resolved clearly in my mind.  To be clear:  We do have a QDRO procedures policy that came with our document system and we follow it when we get a DRO or a QDRO that we can recognize as a DRO or QDRO.  We had only ever seen a separate document, clearly labeled as a DRO or QDRO, that generally contains most of the ingredients in the recipe and mostly never asked for anything the plan doesn't allow.  All we have ever had to do is decide whether a DRO in draft form was complete, or a QDRO processed without us actually had been done right.

The little 3 sentence paragraph I quoted from this case is a part of a 3 page Marital Settlement Agreement that covers children, spousal support, property (just a couple of cars), child support, insurance, income tax, "retirement", liabilities, debts and fees.  They both signed it.

We were struggling with and still struggle with our obligations given that at first, we were told that no DRO and no QDRO would be forthcoming.  If all we would ever get was that one little paragraph, what were our obligations and what were the obligations of our client?  Plus, we didn't realize that until we got a proper QDRO, we would be obligated to honor the request of the participant if he wants to withdraw his entire account.

Now if I understand you correctly, you are saying that the little 3 sentence paragraph was a DRO, in and of itself, and that's what I was afraid of and needed to have clarified.  We can't afford to just blithely ignore this document and say that until we get a proper QDRO, we have no obligation to do anything.  

We are back to this:  If we as a TPA know that a former spouse has a right to a portion of a participant's account, we cannot ignore it.  Anything we get in the future, even if it is just one paragraph, will be suspected of being a DRO, and we will follow the procedures until it becomes a QDRO.  And apparently, if we never get the QDRO, then the participant can withdraw his entire account if he has an event that allows for distributions, and the fight is then between him and the ex-spouse and we have no further liability.  

We have not yet heard back from the participant as to what he wishes to do or whether he was successful in getting his home-made QDRO approved or in line to be reviewed.  I will update the column when we find out.

 

1) No way that 3 sentence paragraph is a domestic relations ORDER (DRO).  An order is an order of the court; I would suggest that doesn't rise to an order of the court. You have not yet received a DRO to determine if it is a QDRO, and clearly this is not.

2) More important, it doesn't matter if is it a DRO; it clearly is NOT a QDRO, and that's what matters.  A DRO and a QDRO are two different animals (A DRO can be a QDRO, but as we all know, it often is not and has to be perfected).  

Here is the language from our QDRO Procedures:

Procedure prior to receipt of order: The Plan will apply the following procedure prior to the Plan's receipt of a Domestic Relations Order.
1. Suspension of Participant distributions or loans. If the Administrator is on notice (verbal or written) regarding a pending domestic relations action (e.g., a divorce) and has a reasonable belief the Participant's account may become subject to a QDRO, the Administrator may suspend processing the Participant's distribution or loan requests pending resolution.
2. Removing hold on the account. After placing a hold on the account, the Administrator should notify the Participant of the hold on the account. In order to remove the hold, the Administrator should request the Participant to provide written confirmation that a court will not issue a QDRO with respect to the account; such as a property settlement agreement awarding the entire account to the Participant.
 

So, we have an OPTION to suspend processing, but are not required to do so.  We also have the option to suspend processing and if it is not resolved in some short period of time (say 60 days), we can lift the hold and do the distribution.

So you can (hopefully) do the same (assuming your QDRO procedure would allow); tell the parties that what you have been given so far does not meet the requirements of a QDRO and they have XX days to get the order to you, and if not received in that time, the hold will be lifted and distribution made to the participant.

Lawrence C. Starr, FLMI, CLU, CEBS, CPC, ChFC, EA, ATA, QPFC
President
Qualified Plan Consultants, Inc.
46 Daggett Drive
West Springfield, MA 01089
413-736-2066
larrystarr@qpc-inc.com

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As a Moderator, I'll take this opportunity to comment about a previous post/exchange in this thread.  Let's keep our discussions civil.  Please.  You know who you are.

There is no value here in using demeaning words or phrasing. 

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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We spent most of today archiving old files and packing away boxes, so I can't do any of you justice at the moment.  @Larry, Starr your latest post helps immensely and I will answer it as soon as I can.  @ fmsinc, I didn't get to read the whole memo yet but the chicken soup story was great!  @david rigby, thank you.  @BobbyV, yes they do.

Have a great weekend, everyone!

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Good morning to all!  Still no word from the participant. 

Larry Starr, you said:

"Procedure prior to receipt of order: The Plan will apply the following procedure prior to the Plan's receipt of a Domestic Relations Order.
1. Suspension of Participant distributions or loans. If the Administrator is on notice (verbal or written) regarding a pending domestic relations action (e.g., a divorce) and has a reasonable belief the Participant's account may become subject to a QDRO, the Administrator may suspend processing the Participant's distribution or loan requests pending resolution.
2. Removing hold on the account. After placing a hold on the account, the Administrator should notify the Participant of the hold on the account. In order to remove the hold, the Administrator should request the Participant to provide written confirmation that a court will not issue a QDRO with respect to the account; such as a property settlement agreement awarding the entire account to the Participant.

 

So, we have an OPTION to suspend processing, but are not required to do so.  We also have the option to suspend processing and if it is not resolved in some short period of time (say 60 days), we can lift the hold and do the distribution.

So you can (hopefully) do the same (assuming your QDRO procedure would allow); tell the parties that what you have been given so far does not meet the requirements of a QDRO and they have XX days to get the order to you, and if not received in that time, the hold will be lifted and distribution made to the participant."

This addresses our whole problem.  Our QDRO procedure, which came with our document software, has no such provisions.  It begins with "Promptly upon receipt of a domestic relations order, the Plan Administrator will....." And that's how the whole mess got started.  We had not been served with a domestic relations order, at least not anything we could recognize or identify as a DRO, and that rendered the rest of our procedure useless.

What you have is perfect.  

Larry, if I send our "canned" procedures document to Word as a rtf file, I can edit it.  May I add on your paragraphs to our procedure without being in violation of something or another?  Would you mind if I do that?  It will be of great help in the future.  Meanwhile I am going to contact the Nice Document Lady at our document software provider's office and suggest that they work on adding this feature to their "canned" document.

Thank you very much for this.

 
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You will not appreciate this, but I recommend not adding a provision that requires judgment and discretion into a legal scheme that does not require that of the QDRO fiduciary (yes, you very well may be putting yourself into fiduciary status by what you are doing in QDRO processing).

You may consider this to be a rude insult, but if you know what you are doing, an objective (meaning no discretionary judgment) checklist approach is best. It minimizes exposure to fiduciary liability. If you are not deeply knowledgeable, then adding discretionary judgment is a bad idea.  It is better to have an objective checklist procedure and then seek advice when the strange event that does not fit arises.

From other traffic in this category, we know that Larry Starr’s clients generally involve Larry Starr in the QDRO processing, so it is safe because the fiduciary has an adviser with deep knowledge to provide protection to the fiduciary that has the duty to make discretionary judgments, voluntarily taken on by unnecessarily adding the provision to the written QDRO procedures.

 

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16 minutes ago, Mike Preston said:

To add to the confusion, OP seems to be clinging to the idea that the original 3 page settlement agreement is not a DRO.  Does everybody agree with that?

I guess my question would be:  So what if it is?   Based on all the descriptions it clearly isn't a QDRO.  

If they have a procedure that says if they get a DRO they can put a hold on the account I guess I can see this being enough to put the hold on the account until the time is up or they get a QDRO.  

 

But strictly speaking I am not sure I have seen a legal definition of a DRO.  

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