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1.411(a)-11(e)(1) is the authority to which ESOP Guy and RatherBeGolfing refer.

If the sponsor does not want to change to daily valuation, ask if they want to change to quarterly. If so, then make sure you can get whatever information you need on that basis. Not a perfect solution, but it avoids the pitfalls of a "special valuation".

Yes, but answer depends on circumstances. Short answer, if the plan does not 1) offer annuities and 2) the employer (or related ER if a CG) does not offer any other DC plans, you can distribute without consent even if the account balance exceeds the plan's cash out limit. Even if you don't fit that answer there are ways to do it, just not as simple.

I'd be speaking with the client (unless he IS the client) and letting them know the issues he is causing. This is unacceptable! Even with balance forward, it shouldn't take 9 months to get you data/earnings that should be coming much sooner. Even when we did annual balance forward back in the day, we still got monthly trust/earnings statements and contribution/loan payments so we had an idea on transactions/balances throughout the year and could have calculated earnings midyear for a distribution if need be -- some plans did distributions quarterly even though they only did valuations annually. But then again, we also did all the trust to plan reconciliations for our clients. I don't ever remember a client where an accountant was involved honestly in any of the balance forward plans we did.

Yes plan termination is one of the few times you can force everyone out. The plan amendment terminating the plan hopefully allows for it. Some people might make the case the amendment doesn't have to say so. The law is clear you can do it. But in the end you can force the money to an IRA set up in this person's name. They can't hold the plan hostage.

The IRS says the following with respect to the compliance questions on one of their websites: "The IRS added compliance questions to Forms 5500, 5500-SF, 5500-EZ and Schedules H, I and R. The IRS has decided that filers should not answer these questions for the 2015 and the 2016 plan years when completing the forms:" That includes the new paid preparer information and the other compliance-related information. So it's the 2017 year filing, at the earliest (generally due beginning mid-2018). For those so inclined, that allows that much more time for retiring early. The url is https://www.irs.gov/retirement-plans/irs-compliance-questions-on-the-2015-and-2016-form-5500-series-returns.

Unanswerable question for me. Totally dependent upon facts and circumstances. If the gain or loss is small, then I'd just pay them out. If gain or loss is large, then you have to consider the issues already discussed. "Small" and "large" gains are in the eye of the beholder, so I can't give you any hard number. You give it your best shot, and present the alternatives to the Plan Administrator, who will then decide. Or more likely, ask which alternative you recommend...

Thoughts? Get paid in advance. After that. Sure prepare 1099-Rs for the actual years the distributions occurred. There may be some late filing fees. Best of luck.

Under the rule (29 C.F.R. § 2520.101-3), the notice must include the required information and “be written in a manner calculated to be understood by the average plan participant[.]” It’s possible to do so without using the word “blackout”. The rule itself defines “blackout period” as a period in which a participant, beneficiary, or alternate payee is temporarily restrained from doing something one could do in the plan’s ordinary administration. So translating “blackout period” as “no-transaction period” might, if it’s factually sound in the plan’s circumstances, be a sensible label (assuming the notice also includes the required information).

Eligibility is 6 months with monthly entry.

In the case of a governmental plan, it would be based on the plan document, except to the extent that applicable state law would require crediting of interest. Of course, since the idea behind DROP is to encourage people to stay beyond when they could otherwise receive retirement benefits, not crediting interest could undercut that goal.