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Pam: In the scenario you describe (abandoned plans or "removed" fiduciaries) I agree with you - but with "routine" admin, can you explain why the 3(16) is more efficient than non-fiduciary outsourcing of that stuff? We do distributions (all kinds) mandatory cash-out processing, DRO review and "Q"DRO-ing, loans, and a whole lot of other stuff without being a fiduciary, and without obtain a plan sponsor/fiduciary signature on anything (except the initial authorization to do so) - unless there is an issue. We try (mostly successfully) to not let those mistakes happen that next year will need correcting. I'm not knocking your business model - but I have yet to see a 3(16) tell me why a "fiduciary" is necessary for the 95% of the stuff we do as a non-fiduciary.

I had a hot dog last night that was ketchup eligible...

I tend towards cowardice on this issue when it comes to pushing the very edge of the envelope. I have visions of IRS auditors packing .44 magnums and saying, "Go ahead, make my day."

A new demographic category.

There do seem to be quite a few folks in the same age range among my acquaintances in this business. (Dave, I'm right behind you.) Years ago, I recall working in a small office with about a dozen other women and thinking it was going to get really ugly when we all started getting hot flashes at the same time. The young people that I meet in the retirement business seem to be going into sales and investment advice more than administration. As we were looking for someone to add to our team last year, we only had one applicant who wasn't catch up eligible.

I feel old. I hit that milepost last year.... Two things about getting older: 1) It beats the alternative; and 2) (as my mother used to say) - "it ain't for sissies."

Bright side - You are still a long way from a trip to RMD-Land.

Now that we know your DOB, can I get your SSN and mother's maiden name? A PM will do. No need to publicly just throw it out there...

Happy 59 1/2! Last year I hit 55 and a co-worker innocently enough said, "now you're eligible for early retirement", to which i responded, "what're you trying to tell me?"

oh Dave, you are such a youngster. typical, thinking you are so special being able to avoid the penalty.

I'll be eligible not too many months thereafter, but really, how far is $150 going to get me? I'd just be glad to have more hair - regardless of the color!