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It's common but I don't think it is required. I'd push back and ask why it's so important to take it off... Personally I think it's a good idea to have "IRA FBO..." or similar language so the participant can't deposit it into an after-tax account.

Thank you both for your input. There was no problem, I issued the check as requested. I've always had the understanding the FBO was indeed required, but after 24 years in Pension Administration I find I know very little...so I was just curious as to other professionals' opinion.

they show up in the ACP test. assuming everyone can make after tax contributions then if plan has last day provision for match (or hours requirement) some people who normally would not show on the ACP test are now included as well with 0%.

Whose error activated the record keeper’s election function? When did the activation occur relative to instructions for elective deferrals? Describe how the instructions to the payroll system election function were presented to participants and eligible employees. For example, were the instructions to use the payroll election function in the SPD? Elsewhere? What else are employees instructed to do through the payroll system? What record keeper functions were officially usable by participants and how was the sanctioned use presented? Investment instructions? Who is the plan administrator and what role did/does the PA have in any of the policies and communications relating to participant elections of all sorts (e.g. beneficiary designations)?

As a general rule I don't respond substantively to posts that refer to an actuary as an actuarial.

Not trying to point out the too obvious but the defaulted loan counts as a loan still so if the loan policy limits a person to one loan at a time they couldn't take another loan. Or at least that is my memory of the rules as it has been over 10 years since I last did a 4k loan.

The stale check is a plan asset, I don't see how you can reject it. I would request that the prior provider hand over whatever information I need to take care of the assets though. I have had this happen before because some investment platforms have more than one step in a distribution. Basically the provider takes the amount from the plans account, and makes the payment from a provider account. As far as the plan can see, the payment "cleared" when removed from the plan account. On the provider side, the payment from their account goes stale so the amount remains in that account rather than being returned to the plan account. This is one of the issues in the missing participant debate. It gets even more fun when you add overlapping plan years and withholding...