david rigby

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Based on that sentence, IMHO, the entire beneficiary form has been revoked.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

A brief caution: make sure (when returning the check) that you emphasize the nature: spell out Required Minimum Distribution, as well as the taxability. (Perhaps this has already been done, just being cautious.)

Think outside the box. Does it help or hurt the goal to limit the allocation to the husband?

Ask the accountant if he/she has a cite for this. (This might be another way of saying, "so what?")

Data as of 03/29/2019 (Friday) Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 3.62 3.62 Aa 3.81 3.70 3.76 A 3.99 4.01 4.00 Baa 4.49 4.84 4.67 Avg 4.10 4.04 4.075 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 2.24 Medium-Term (5-10 yrs) 2.35 Long-Term (10+ yrs) 2.73 Observation: comparing the Avg line to 12 months prior, current rates are 5-8 points lower. Comparing the Avg line to 6 months prior, current rates are about 30 points lower.

FICA wages of $18K, but zero FICA withholding? Is that possible?

To the original poster: Please do not send any personal information to this person - or anyone else - until you have vetted the person/company. Anything you send should have a password or some other security.

OK, there is (or soon will be) a union (including the good faith bargaining characteristic). That does not require a new plan. The company (and maybe the union itself) should consider the pros and cons of creating a new plan vs. using the existing plan. It's also true (seen it many times) that the union might want neither of those alternatives, so it's good to get advice from someone who has broad experience in qualified plans.

At the risk of going off target, there have been many questions posed on these Message Boards that misuse the word "sold". If the company was sold (complete stock sale, not asset sale), that does not require the plan to terminate (probably), and may not result in a plan termination. The original poster should make sure to know the true nature of the transaction.

Has anyone posed these questions to the signing actuary?

Have you considered whether an adoption exists? (PS, sometimes the kids don't know about it.)

No disagreement with Luke's comments, but consider the intersection of PA interpretation and HR policy. Easy to imagine that the PA would prefer looking to existing policy(ies) rather than create them.