Leaderboard

I vote that you can't do it, but I wouldn't resign from a case where the client decided to go ahead as long as the client was getting advice on the issue from ERISA counsel.

1. He met the age requirement on the entry date 7/1/15. 2. Having worked 1,000 hours in the plan year 4/1/14 - 3/31/15, he met the service requirement no later than 3/31/15 (depending on how the plan is worded, it could have been prior to the last day of the plan year). In any event, as of the entry date 7/1/15, he had met the age and service requirements and would have become a participant on that date. If he were older and met the age requirement some time in 2013 or earlier, he would (depending on the exact language of the plan) probably not be able to enter until 4/1/15 because that would be the earliest quarterly entry date on which he would have met both the age and service requirements.

If not 7/1/15, then the next quarterly entry date of 10/1 I would think.

This is a serious question because in my line of work I don't get down that deep into the record-keeping trenches, plus I am not sure we have any clients with DC plans that are not self-directed. Can a pooled plan be daily valued, given the technology available in this day and age (assuming no "hard to value" investments), with distributions processed at any old time during the year? Seems to me that is the most ideal scenario for participants generally.

Unless the amount to be paid is in balance with the value of the underlying assets as of the time the distribution is to be paid, someone is being shortchanged and someone is being overpaid. Good reason to only allow distributions coincident (or nearly so) with proper valuations. If you are going to only value the assets once a year, only allow distributions once a year. Still hard to understand why, in 2016, daily valuation is not standard. Not being able to value the assets based on the market each day either points towards inadequate technical capabilities on the part of the asset holder or towards the holding of investments not suitable for a defined contribution plan covering more than one person (assuming, as someone who does not handle such plans, that hard to value/illiquid assets make more sense in one person plans than they do in plans covering more than one participant).