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just want to add that it smells like a document failure; generally those are not eligible for self-correction.

1. You can’t close one 401(k) and open another less than 12 months apart for the same business (which this is because of controlled group rules). The real issue is whether the document allowed you to count any contributions from the new entity since it didn’t adopt the plan in 2022. That’s a document issue that Vanguard has to answer. 2. There’s a place on the 5500 to show that the prior 5500 was filed under a different EIN. 3. I recommend you hire someone that does this work and not try to resolve it yourselves.

This is indeed important detail. I triple down on my suggestion that the Plan Administrator hire counsel. Bad advice was given, bad advice was taken, and bad advice led to unfortunate consequences - for the granddaughter, for the son, for the Plan Administrator, for the plan sponsor, and perhaps for the 3rd party advisor. We cannot resolve those issues here...

Thanks. My point is that, even for a plan sponsor that uses an IRS-preapproved document, spending a few minutes at the plan-documents stage—to read the default-beneficiary provision, or even without reading to replace that default with the plan sponsor’s preference—can save lots of foolishness later.