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Restatements, trust documents, and recordkeeping platforms


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I want to see if this is just us, or are others encountering similar things, and also to get other perspectives on the issue - maybe mine is skewed.

This week , we have received notifications from a couple of vendors/recordkeeping platforms. To paraphrase succinctly, they are saying that due to the fact that Trust Provisions are no longer in the IRS pre-approved documents, that we need to notify them (the vendor) and send them a copy of the PROPOSED plan restatement provisions, at LEAST 30 days prior to sending them a copy of the restated plan. This so they can "review the provisions" to make sure they can handle the plan. For all I know, this may be something that many vendors are doing. And these are plans where the employer is the Trustee, or it is a corporate Trustee.

My feeling is BS on that. It is hard enough to do these restatements and coordinate with the employer, without getting the VENDOR to approve the choices. As far as I'm concerned, we do the restatements as usual, (after getting employer approval of any changes) and send the completed document to the vendor afterward. If they have a problem with it, we can amend the plan, or the employer can find anther vendor if the vendor won't handle the employer's desired provisions and it is important enough to the employer.

I should also state that the changes that employers are making are nearly always basic things - maybe eligibility, or adding or removing hardship withdrawals, etc. - normal things that are handled all the time by vendors when plan amendments are completed anyway.

Maybe I'm just grumpy and unreasonable this morning. Have you been seeing anything similar, and if so, any thoughts? Thanks.

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reminds me of the plan I have with in-service distributions at age 62.  the client moved the plan to one of the larger 401k vendors and I was completing the set up checklist.  There wasn't an option for an age indication on the in-service withdrawals.  When I questioned how to complete that section I was told that they only have set up for in-service distributions at age 59 1/2.  Since both I as TPA and the client had to approve all withdrawals, the vendor told me that it would be set up as 59 1/2 and then the client and I would have to review and deny any that were requested between age 59 1/2 and 62.  Apparently they must never deal with disgruntled participants who would ask why was the option available online at 59 1/2 if they aren't eligible until they are 62? (she said with sarcasm!!!)

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We got the same request from a large platform recordkeeper, for which the platform company also serves as the plan's trustee.  We told them essentially what Belgarath is saying, and asked them what they were looking for.  They sent back a list of about 6 specific items that they would be looking for when reviewing the plan documents.  I'm not sure how we will handle this yet...

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