Leaderboard

We are still reviewing this to determine whether we want to offer it to our clients. Most of our clients use our outsourcing services where we collect an review the necessary documentation to determine if the need exists - so whether it is implemented or not, it won't have must impact on our clients - except for the occasional gripe from a participant who complains (but - they are generally the one who actually don't meet the criteria for a distribution.) Our concerns, as have been mentioned, are the "actual knowledge to the contrary" provision, and whether an employer's knowledge is imputed to us, as their agent under our outsourcing; the potential for abuse (and if/when a serial requester can be determined to be abusive and denied); why? I mean the point of a retirement plan is to provide financial resources for retirement - and now we are basically going to allow participants to turn their balance into a Christmas Club account? Leakage is an issue, and this may exacerbate it. Now, that said, my ops team that has to review and process these requests are all in on implementing this. When speaking with clients, I always ask "do you trust your employees to be honest and not abuse the ability this provision gives them?" The reactions are uniformly priceless and in the negative.....

I imagine that the recordkeeper would want the Plan Administrator's acknowledgement that they do not have any actual knowledge to the contrary of the information provided on the participant's self-certification.