Leaderboard

https://www.dol.gov/sites/dolgov/files/EBSA/about-ebsa/our-activities/resource-center/faqs/temporary-implementing-faqs-lifetime-income-interim-final-rule.pdf

Why spend time disproving it? The TPA said the "rules say" he needs to wait, have them cite the rule(s) that says so.

If the plan is not paid out until 2020 then they still have a plan in 2020 even if the plan termination date in the document is 12/31/2019.

Very confusing. Care to try again?

The amount shouldn't matter to this discussion. The client normally relies on the 7 bday safe harbor (deemed to be segregated at the earliest date), the transaction in question took 8 bdays due to unusual circumstances. The question is, did the unusual circumstances cause a small delay during the 7 bday window to make it 8 bdays, or was the 8th bday the earliest time it could be deposited due to the unusual circumstances? If its the former, it should technically be reported on the 5500. If it is the latter, I think you have a reasonable argument for calling the deposit timely and leaving it off the 5500.