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I agree with Bill. The ER may end up making a contribution for the earnings if it was their fault. If the RK screwed up, they should make up the lost earnings.

Necessary is a strong word. Highly advisable yes to comply with tax reporting requirements including PS-58 costs.

I have always understood it was for facts like this that there was the April 1 following rule. People who terminated late in a year it might take a while to determine they are due an RMD. Obviously, there is no practical way to hand him an RMD check as he walks out the door. I think he is due 4/1/2017. That is how I have always recommended it to my clients. He terminated in 2016.

At one of my former companies, if a new TPA (or a new record keeper or even the client) wanted copies of work that was already sent to the client, we would have an hourly charge and postal costs (if mailed, obv.) for the retrieval and duplication of the material. The charge was higher for documents stored off-site. (This was before most things were kept electronically). Work was only delivered after invoice was paid. I see no problem with that practice, as long as the charges are reasonable (and ours were).

Just to get back to the OP's query and the very correct commentary concerning the reasonableness of the fee. We currently charge either a flat fee of $250 or an hourly rate of $150 (depending on our service agreement with the plan) for complete QDRO outsourcing service (the "Q" determination, letters, etc., everything up to an alternate payee requesting a distribution - which is handled as a regular distribution). I think that is low. Average time to complete is about 5 hour - with half of that being "professional" time, and half being more clerical/systems related. Factor in risk, and the price could, and possibly should, be $700 - but market forces being what they are, I think that wouldn't fly.

John, I would lean toward using logic similar to what is found for situations in which plan limits for catch-up contributions are changed These final regulations retain the rule in the proposed regulations that a plan that changes an employer-provided limit during the plan year is permitted to use a time-weighted average of these limits as the employer-provided limit. For example, under this alternative method, a plan that provides for an employer-provided limit of 8 percent for the first six months of the plan year and 10 percent for the second six months is permitted to use 9 percent as the employer-provided limit for the plan year. These final regulations also provide that the plan is permitted to use the definition of compensation used for ADP testing purposes for this weighted-average simplification, and can use this alternative method without regard to whether the employer-provided limit is changed during the plan year. 1.414(v)-1(b)(2)(i)(B)