david rigby

Not quite clear from the OP, did the in-service distribution and the retirement both occur in the same year?

Data as of 04/30/2019 (Tuesday) Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 3.71 3.71 Aa 3.87 3.78 3.83 A 4.05 4.05 4.05 Baa 4.49 4.80 4.65 Avg 4.14 4.09 4.12 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 2.26 Medium-Term (5-10 yrs) 2.43 Long-Term (10+ yrs) 2.84 Observation: comparing the Avg rates to 12 months prior, current rates are 14-19 points lower. Comparing the Avg rates to 6 months prior, current rates are 49-55 points lower.

Is the plan audited? Is there a service agreement? The Plan Administrator may wish to engage ERISA counsel.

It's not clear the widow's best interest is served via using a QDRO. Wouldn't her benefit be maximized by ignoring the QDRO?

Maybe that question should be answered first?

If "we" is the TPA, and there is also a prior TPA, consider the possibility that you might not have all the information about one or more of those accounts.

Don't forget that a money purchase plan is a pension plan. I've seen MP plans restated to be a traditional defined benefit plan. Is that relevant to your situation?

Google get you this: https://www.bizapedia.com/tn/american-preferred-life-insurance-company.html Tennessee Department of Insurance: https://www.tn.gov/commerce.html I don't know this company, so am unsure if it's what you need.

Does (3) have any bearing on the QDRO?

I'm curious, would you inquire as to whether the participant understands that term?

Reasonable expenses.

Don't you first have to determine Key vs. Non-Key?

Pardon the skepticism. This change is pretty unusual, and unlikely to be discriminatory (best guess). However, is the ER trying to accomplish something in particular. (That is: what is the goal, then let's see how we can get there.)

Are you harmed?

… and maybe learn from administrative mistakes, to minimize them in the future.

… assuming your plan is not subject to the rules (or lack of rules) that apply to a governmental or church plan.

Can you consider (effectively) making a new loan, replacing the current one with a faster amortization schedule? (It just might make your payroll system a little happier.)

Although not recent, I've seen it happen.

A discussion in the Litigation message board that may also be of interest to readers of this QDRO message board. https://benefitslink.com/boards/index.php?/topic/64088-alternate-payee-dies-before-qdro-does-his-estate-have-a-valid-recovery-claim/

Based on that sentence, IMHO, the entire beneficiary form has been revoked.

Is "contingent" defined in the original beneficiary designation or in the plan?

As mentioned in the reply from Lou, the issue isn't really the number of data discrepancies, it's the materiality. For example, it might be possible the male/female identifier is wrong for 50% of your population and the resulting liability is off by 1% (or less). While sampling is a good start, it does not tell the entire story. Talk to the actuary!

Some plans have a "deductibility clause". Relevant here?

Just in case, "competent advice" means you will need an attorney with experience in domestic relations law. BTW, the RRB might use the term "court order" rather than DRO.

Do you find an exemption in IRC 401(a)(9)?