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There is an undeniable duty on the part of the sponsor to maintain adequate records. The sponsor, who is your client, really must be able to provide you whatever information is needed for you to perform your duties properly. Granted, it's an imperfect world, but that does not, by itself, excuse negligence on the part of the plan fiduciary. Sorry if I am on the grouchy side - it's been a tough week.

From the regs under 1.415©-1 (B) Date of employer contributions. For purposes of this paragraph (b), employer contributions are not treated as credited to a participant's account for a particular limitation year unless the contributions are actually made to the plan no later than 30 days after the end of the period described in section 404(a)(6) applicable to the taxable year with or within which the particular limitation year ends. If, however, contributions are made by an employer exempt from Federal income tax (including a governmental employer), the contributions must be made to the plan no later than the 15th day of the tenth calendar month following the end of the calendar year or fiscal year (as applicable, depending on the basis on which the employer keeps its books) with or within which the particular limitation year ends. If contributions are made to a plan after the end of the period during which contributions can be made and treated as credited to a participant's account for a particular limitation year, allocations attributable to those contributions are treated as credited to the participant's account for the limitation year during which those contributions are made.

You are absolutely correct. It may be inconvenient and costly to recreate the wheel, but you really have no other choice. This is information they are required to have and are required to provide on the return. Absent a fire/flood/[insert disaster here] that destroyed all paper and electronic records of the documents needed, I can't think of a reason why it can't be done.

I guess I am having a hard time on how they don't know the ending balances. How did someone produce the participant statements for those years? The ending balances in a 401(k) plan ought to be the sum of those statements. Once again did they produce W-2s? They had to know the 401(k) amounts then. Have the payroll records been lost? Did they take a deduction for any match on a tax return? As noted above the world is imperfect so I can see how after years the data might no be as easy to get as one would like but it seems like the data has to exist.

Full disclosure here I am a DC not a DB guy. However, my basic take on this before any of the DB experts commented was like My 2 cents (I waited to reply to see if there was any unique DB issues the DB experts would bring up) -- The sponsor/administrator signs the Form 5500 they get the final say on how it reads. So unless you can show what they want is some kind of reckless disregard for the law that could harm your practice I don't see a good reason for the sponsor's wishes to not be the final result. I can see why you might want to document why you think your answer is the better answer with the client but the TPA isn't the plan sponsor or plan administrator.

The decision to make a change from using a cash basis to using an accrual basis for 5500 purposes (assuming that such a decision can be made without governmental acceptance) is, clearly, one that belongs to the sponsor. How could the service provider think the decision was theirs to make? If past practice was to report on a cash basis (recognizing that Schedule SB reporting is never on a cash basis), there would be no compelling reason to switch just so the 5500-SF (or Schedule H if a larger plan) would match the Schedule SB. Note that if there are receivable contributions, the market value on the Schedule SB will NEVER match the 5500-SF or Schedule H beginning balance, since the former would include the receivable contribution on a discounted basis but the latter would include it on an unadjusted basis. True, it used to be expected that they would match, but since PPA became effective, the SB must reflect for all purposes a discounted value for any receivable contributions.

whyindaheck, I would complete the form through the section on surviving children and leave the parts asking about siblings blank. If your sister doesn't want to provide her SSN for the form, leave it off of the form. It can be provided later. Then, see how Fidelity responds. As mentioned, dealing with Fidelity usually tests your patience.

Fidelity is being Fidelity - just asking for anything and everything, whether they need it or not. With the caveat that we don't know if the plan has a default bene des that effectively names you and your sister, I'd either ignore the siblings page or write "not applicable" or something to that effect. If they don't like that and say that they need the info, you're going to have to ask "why" because it really is irrelevant. And "because" is not an acceptable answer - they should not be creating artificial impediments to you receiving your money. Don't be afraid to argue with them.

What you are describing is commonly referred to a s true up match. What is sometimes done is you do the match per payroll, at year end you calculate the match an employee would have received under and annual match based on annual pay and annual deferral and subtract out what has already been deposited under the per payroll matching for the year. What is left is the remaining deposit for each employee. This should be in the plan document I believe and as others have said you have additional caclulations so often additional expense.

Perhaps, once you get this straightened out, Fidelity (or the Plan Administrator) will allow your sister to provide her SSN directly to them, so you won't see it? Maybe, for whatever reason, she just doesn't want you to see it...