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SSA Transferred Participant Question


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I have a question about how to report the transferred participants on the SSA when the same company created a new plan and transferred some of the participants to that plan.


So, the same company is sponsoring both plans. The first plan (Plan Number 001) transferred some participants to the second plan by the same employer (to Plan Number 002). The SSA instructions seem to indicate that the transferred participant must be terminated to be included for the SSA purposes (here's the language from the SSA instructions: "When the benefit of a separated participant with deferred vested benefits is transferred from one plan to the plan of a new employer"). Since these participants are not terminated (they are still employed by the same company, but are now with the other 401k plan by the same employer, would they need to be included in the SSA?



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If you have old terminated participants who were previously reported on SSA you'll want to remove them from t he old plan and report them on the new plan.

But if they are active employees, I agree with Bill Presson. Doesn't seem to be anything to report unless they separate from service with vested benefits.

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