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agree. Furthermore, althouth it is legal not to give an interest credit until the end of the year, as an actuary I have an issue with that. Seems like a loss of "economic value" to me, and I do not like it; we normally use a "pro-rata" approach.

Seems like it is to me.

Are you looking to change how to pro-rate excess assets upon PLAN termination, or is it a case where you're looking to only pay the 12/31/23 hypothetical account balances and not 11 months' worth of the interest crediting rate for 2024 (for the participant's termination of employment)?

I agree.

Probably. Is that the case?

Money is fungible. The requirement is to refund out of his account. You don’t have to find the specific dollar that was contributed in 2023.

I don't see why not if that's an election she makes and the plan can process 100% tax withholding.

Don't take it as a slam on my part. I was just pointing out how to find it. Please don't be shy to ask questions here. That wasn't the point of my reply.

https://www.irs.gov/pub/irs-tege/epchd704.pdf Have you checked out the IRS manual, if you look on 7-46 there is an ASG flowchart. I like it.

Been there on several occasions. Normally I would send the docs an “easy read” on ASG from ASSPA and a hard one from IRS and point out a few most relevant slides with a closing recommendation to engage an ERISA council. It is what it is.

You will be shocked to find that the doc is not happy that be might be part of an ASG. "I read up on it this weekend" - great; I've been reading about it for 30 years and it's still really complicated. "I'll open a SIMPLE IRA instead and forget this!" Buzz! Sorry, also subject to ASG rules. I don't think I'm getting this business.

Doctors can be wrong? Yes, have them engage an ERISA attorney and wait for the doctor to say “But that’s not fair!” - which was the funniest thing I’d heard that day.

A plan sponsor, an employer, or a plan administrator might prefer to show as its address an address at which the person wants to receive mail. It could be bad if EBSA or IRS sends a notice to the address shown on the most recently filed Form 5500 report, the employer or administrator does not get the notice, and is charged with having failed to respond timely to the notice. I have worked on matters in which the plan’s administrator, as a safety caution, was unwilling to show an address of where the employer or administrator worked. In one, the Form 5500 reported a lawyer’s office address. In another, the administrator rented a Post Office box and put that address on the Form 5500. This is not advice to anyone.