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Who wants to herd a hundred cats, I mean, sole proprietorships?

For recordkeepers that have managed accounts, gender is a piece of information that is useful for the life expectancy to determine how long the assets need to be available in retirement. While not a perfect fit, gender is also nice to have when someone calls into the call center and the name of the account is Nancy, but the voice sounds like Fred - that is a "flag" to watch for possible fraud. I was also thinking about beneficiary forms, but that has more to do with the collection of Married or Single information.

I think the concept is fine. For testing purposes, this should produce a uniform dollar amount of contribution for all participants, so would meet the safe harbor.

If the plan sponsor is not in a chapter 7 liquidation bankruptcy, a termination administrator is a qualified termination administrator “only if: (1) It is eligible to serve as a trustee or issuer of an [IRA], and (2) It holds assets of the plan that is found abandoned [under the QTA rule].” 29 C.F.R. § 2578.1(g) https://www.ecfr.gov/current/title-29/part-2578#p-2578.1(g). Otherwise, a Federal court appoints an EBSA-selected cleanup fiduciary when no one applies to serve as a QTA (or none is eligible), no bankruptcy trustee or insolvency receiver serves, and the Secretary of Labor, acting by the Solicitor of Labor, brings a civil action. (The Labor department makes policy and strategic decisions about which situations to pursue, and which to ignore.) A District Judge typically follows Labor’s suggestion on who should serve as a cleanup fiduciary. Some trust or insurance companies volunteer to serve as a qualified termination administrator; some don’t. You might be in luck; Voya serves. https://www.askebsa.dol.gov/AbandonedPlanSearch/UI/QTASearchResults.aspx If you know the plan’s administrator’s contact at Voya, consider starting there.

The § 72(t)(2)(A)(v) exception from a too-early tax applies to a distribution “made to [the participant] after separation from service after attainment of age 55[.]” http://uscode.house.gov/view.xhtml?req=(title:26 section:72 edition:prelim) OR (granuleid:USC-prelim-title26-section72)&f=treesort&edition=prelim&num=0&jumpTo=true The IRS recognizes a practical tolerance about the age-55 condition: “A distribution to [a participant] from a qualified plan will be treated as within section 72(t)(2)(A)(v) if (i) it is made after the [participant] has separated from service for the employer maintaining the plan and (ii) such separation from service occurred during or after the calendar year in which the employee attained age 55.” IRS, Employee Plans-Miscellaneous Tax Reform Changes, Notice 1987-13, 1987-1 C.B. 432, at § D, Q&A-20. But the tolerance about the age-55 condition does not change the separation-from-service condition. This is not advice to anyone.

That is so cool!

Section IRC § 401(k)(14)(C)(w)(t)(f), provides that you will be removed from you home at night and placed on an airplane that will take you to a prison in El Salvador without due process where you will be incarcerated for the rest of your life. So your best course of action to protect yourself is to interrogate the prospective lying SOS in the customary way before permitting the hardship distribution. https://www.meisterdrucke.uk/kunstwerke/1260px/English%20School%20-%20Cuthbert%20Simpson%20also%20Symson%20Simson%20or%20Symion%20tortured%20on%20th%20-%20%28MeisterDrucke-673723%29.jpg