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I'd resign regardless of whether they ultimately decide to correct or not. Life is too short to deal with this type of client. We would certainly seek counsel re our obligations to report or not report, etc. Rock - TPA - Hard Place.

If you are a member of an organization with a code of conduct (e.g., ASPPA) and/or subject to Circular 230, I would consult those resources concerning professional and legal obligations.

Is the plan top heavy?

yeah it was a credit card limit. the fee was $4,000 so that was pushing them over their cap.

It's unclear to me what you mean by a "Lump Sum withdrawal" ? Do you mean a "lump sum" of 12 monthly payments ($2,000 each), or a "Total Distribution" of his entire Accrued Benefit? If he is NOT terminated, does the plan permit In-Service Withdrawals of his entire Accrued Benefit? If this is a total distribution, and the plan allows In-Service Withdrawals, the total distribution might be worth around $264,000 (2,000 x 12 x approx 11 [APR] ). If by "lump sum withdrawal", you just mean 1 annual payment (vs. 12 monthly payments of $2,000) you should be able to pay a $24,000 annual RMD payment before 4/1/2023, if plan document allows annual payments of the RMD's. P.S. you didn't say whether the $1,000 / $2,000 AB's were monthly benefits or annual benefits, but the discussion implied this was a Monthly Accrued Benefit. .... Jeff

If plan permits, s/he could take an annual annuity form, so a little less than 12x the monthly benefit (actuarially determined based on annual annuity factors). The 9x (etc.) multiplier does not satisfy equal payments requirement. If s/he is eligible for in-service distrbs under terms of the plan, then electing a lump sum might be an option. Most of the L/S can be rolled over to IRA or PSP, with RMD portion (must be distributed instead of rolled over) calc'd under modified DC rules. Look for Single Sum distrb rules in 1.401(a)(9)-6.

You should probably take a look at 1.401(a)(9)-6. If they are taking a lump sum, they have some options.

? What is the objection? If you have a plan with $1M in it, and one participant has $800K, and that participant asks for a distribution after the plan has lost 20% of its value since the last regular val date, are you not going to do a special val?