A participant passed away in 2020. The family and employer just notified us in 2022. One of the beneficiaries is a Trust. The claim form states that "The Trustee of the Trust must certify whether the underlying trust beneficiaries are designated or non-designated beneficiaries as defined by Section 401(1)(9)(E) of the Code. The trustee must provide the certification by October 31st of the year immediately following the participant's death." Since 2 years have passed, what is the impact of the trustee not having met that October 31st certification date?
