david rigby

Enrolled Actuary I might be biased.

Why? The plan administrator is required to provide a notice to VTs, no later than the 5500 filing of the plan year following the plan year of severance of employment. Doesn't that (effectively) put the VT on notice to request the benefit? IMHO, it's unreasonable to expect the ER to do the legwork of tracking down all VTs (assuming they have been properly notified).

I suggest you also consider the possibility of death, and search here: http://ssdi.rootsweb.ancestry.com/ If you get any deaths, then your job becomes more difficult because you have to search for a surviving spouse. The best starting source might be an online obituary.

As permitted by the plan? QDRO cannot create this mechanism of distribution.

Data as of 31-AUG-11 (Wednesday) Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 4.41 4.41 Aa 4.48 4.54 4.51 A 4.74 4.86 4.80 Baa 5.33 5.62 5.48 Avg 4.85 4.86 4.86 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 0.43 Medium-Term (5-10 yrs) 1.25 Long-Term (10+ yrs) 3.05

Is there a RMD problem to deal with?

EOY is almost always best. The IRS was asked the question about whether 12/31 is different than 1/1 as a merger date, at an Enrolled Actuaries meeting a few years ago. Response: as long as the intent is clear, they don't care whether the merger date is 12/31 or 1/1. Just make sure there are no side issues. This might mean different things to different people. Be careful.BTW, don't forget: - the requirement for an audit is based on participant count. If keeping them separate keeps both below the limit, it may be worthwhile to avoid the merger. - if one plan has "excess assets" (ha, ha), merging be a method to reduce PBGC premiums.

Annuity form = 100% J&S? Why terminate? Got COLA?

Start with PPA section 508, which amended ERISA section 105.

DL?

True. Often this is cheaper than anything else.

Maybe. It's (always) a facts and circumstances test. First, the IRS presumes all terminations during the appropriate time frame are subject to the deemed vesting. Second, the plan sponsor has the ability to document other facts that might exclude some of those terminations. For example, an employee who died.

Make sure you know what you want: in SoCal's link, there are tables known as UP-94, GAM-94, and GAR-94. There are also projection scales to forecast to future years.

Any help here? http://benefitslink.com/boards/index.php?showtopic=48156

http://www.irs.gov/retirement/article/0,,id=123231,00.html

Amen. Another possible reason to avoid the EE deferrals is the increased employee expectation of directing the investments.

Hmmm. What if you recognize 1 year of past service? or 2? Does that produce an onerous result?

Perhaps show the agent a 2008 asset statement, presumably with more detail than the 5500, showing investment losses. This might headoff a larger investigation.

Whose error? sponsor or TPA?

Your tax dollars at work.

Try online search for an obituary. That might turn up a sibling or other relative. BTW, if no beneficiary designation, check the plan for a default definition.

IMHO, there is nothing wrong with this.BTW, if the plan is DB and the previously reported A has begun receiving monthly payments, that person should also be reported as D.

Likely, it depends on administrative practice. I've seen anywhere from 0% to 8% (with appropriate compounding and fractional adjustments).

Maybe. The end of an employment relationship is in the hands of the ER and/or the EE. The ER could label this person as terminated, but also permit him/her to be "on-call" or a contract employee. Do it affirmatively, and consistent with other similar situations. (For example, if the on-call work is steady, the ER might choose to forego any formal declaration of severance of employment.)

Since you now have more information, it does not seem appropriate to ignore it.