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Transfer from Non-ERISA 403(b) to ERISA 403(b)


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Assuming both plans permit such transfers, I do not think so. 

You could have problems with the vendor(s) on the Non-ERISA side.  I have had them refuse to transfer the account or asset without a distribution event. (Document language is, of course, critical.)

More frequently lately, we have been asked to merge the Non-ERISA plan into the ERISA plan (same provider (TIAA)).  (I am assuming your "newly established" plan is ERISA.)  Your idea would be cleaner if the Non-ERISA plan has several different investments funding it.  You would avoid having assets with recordkeeping in various and sundry places with the records not easily available for administration.  Most of mine involve 2 TIAA plans where the asset records are easily available and TIAA is very cooperative.

Hope this helps!

PNJ

Patricia Neal Jensen, JD

Vice President and Nonprofit Practice Leader

|Future Plan, an Ascensus Company

21031 Ventura Blvd., 12th Floor

Woodland Hills, CA 91364

E patricia.jensen@futureplan.com

P 949-325-6727

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