Interesting scenario. I’d treat this as participant rollover contributions in the new plan—not a plan-to-plan transfer—assuming the terminating plan actually processed distributions as eligible rollovers.
The key thing is documentation and traceability. If those amounts were reported as distributions (e.g., 1099-R) and can be tied back to each participant, then track them as rollover sources in the new plan.
If the money never really left plan control or wasn’t properly distributed, it starts to look more like a failed termination than a clean rollover, and that’s a different issue.
Curious how others would handle it if the distributions weren’t clearly documented.
Interesting scenario. I’d treat this as participant rollover contributions in the new plan—not a plan-to-plan transfer—assuming the terminating plan actually processed distributions as eligible rollovers. The key thing is documentation and traceability. If those amounts were reported as distributions (e.g., 1099-R) and can be tied back to each participant, then track them as rollover sources in the new plan. If the money never really left plan control or wasn’t properly distributed, it starts to look more like a failed termination than a clean rollover, and that’s a different issue. Curious how others would handle it if the distributions weren’t clearly documented.