david rigby

Ideally, the reference to "set up procedures" in Post #3 is double-edged: - The external vendor should improve their procedures, and should identify those improvements to you (i.e., the plan sponsor), and - The sponsor should improve its own procedures (let's just call this "proofing").

... and paragraph ©(1)(i)(A), which seems to indicate a PA responsibility to monitor/measure actual receipt of the e-correspondence.

...but they don't have to have the exact same benefit.

Another potential confusion: usually a division of account will exclude any EE contributions/deferrals/PS additions that occur after a particular date (for example, date of separation). The original post makes no mention of that, so the parties should proceed carefully; if ambiguous, the record-keeper should not make the decision.

Well, of course you already know that the participant count is the most visible, but not the only, parameter to determine whether an audit is required.

Right. If the participant pays the AP "by check", is that intended to replace the QDRO? If so, the parties need to get the QDRO changed first.

Sort of. I've seen many qualified plans that have no special provision for disability (no 411d6 protection). Sometimes, vesting is triggered upon disability (in which case a definition is needed). But, it's not required.

I think so. Be sure to investigate the "duration of work" test, which could mean a disabled person is not eligible for SS disability benefits. Summary booklet here: https://www.ssa.gov/pubs/EN-05-10029.pdf

Not so subtle point that the internet already has an infinite number of monkeys.

https://www.irs.gov/irb/2016-42_IRB/ar12.html

Thanks to the internet, we know this is not true.

Well, since we are discussing limits... An infinite number of mathematicians walk into a bar. The first orders a beer, the next orders half a beer, the next orders a quarter of a beer, and so on. … After the seventh order, the bartender pours two beers and says, “You fellas ought to know your limits.”

As I recall, the last upgrade went well. Dave's service to us is greatly appreciated.

It's possible a smaller firm could service this type of plan. Expertise matters.

"...put in for a distribution..." sounds like a claim for benefits. Does the plan have a claim procedure? Does the procedure describe how/when to respond?

The second part of the cushion in 404(o)(3)(A) is (in simple terms) the difference between the UC liability and the PUC liability. Of course, IRC 415 must not be ignored. Your salary scale must be reasonable, but those on this message board don't have any information to assess the reasonableness of 3% for this plan/employer. Just my opinion.

Q. How many people work at your company. A. About half.

Has the plan actuary already contributed anything to your inquiry?

Should the actuary be doing this calculation?

If the owner "deposits $25K", doesn't the plan define how that is to be allocated among all the participants?

Get thee to an ERISA attorney. Pronto.

A phone call may be useful, but don't for get to request they send you the letter acknowledging it has been resolved. Never throw out that letter.

http://benefitslink.com/boards/index.php/topic/56516-db-plan-termination-but-with-a-difficult-participant/

...which may have limited "incentive" if significant number of participants don't, or cannot, access that store.

Any of the accounts below $1,000 (or whatever the mandatory cash-out limit in the plan)? Also possible some of these ex-EEs have forgotten about it? Perhaps a friendly reminder letter?