david rigby

When we say things like "... does the record-keeper permit or allow...", is there concern that the record-keeper starts to look like a fiduciary? - Is there a service agreement that defines this service? - If so, should that SA already address some of these other issues?

Yes. However, there still may be a legal and/or accounting advisor to the employer.

The TPA might also choose to provide a FYI to the sponsor's attorney and/or auditor.

Step 1. Hire an actuary.

Perhaps the PA might consider reversing everything and starting over, especially with a real QDRO?

referring to the DB question.

Might the plan's vesting definitions make this irrelevant?

The reason that ERISA created the requirement to have a written plan document is so that all parties (plan, TPA, participant, etc.) can follow it in uniform manner. There is no "industry standard" that alters the plan provisions. Maybe the sponsor needs a new record-keeper.

Data as of 31-Aug-15 (Monday) Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 4.15 4.15 Aa 4.26 4.18 4.22 A 4.36 4.49 4.43 Baa 5.43 5.28 5.36 Avg 4.68 4.53 4.61 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 1.30 Medium-Term (5-10 yrs) 1.88 Long-Term (10+ yrs) 2.70

Please tell us what these other things are.

Gray Book 2012-5 includes this statement in the question, not in the answer: Gray Book 2012-14 includes this statement in the answer: Thus, the IRS has two indirect references on the applicability of RP 2000-40: Gray Book 2012-14 and Reg. 1.430(g)-1(b). The lack of a simple and direct statement from the IRS to answer this question strikes me as inadequate. IMHO, you may be able to build a case for saying that the permission in section 3.13 is still valid (frankly, I'm shocked that the IRS would not retain this particular permission), not that I'm going to push it.

I'm not so sure it's that simple. Has the IRS stated that Rev. Proc. 2000-40 is invalid? (Maybe they have. If so, please tell me.) Sure, some parts of it are no longer valid (such as all the non-UC funding methods), but that condition may not apply to the entire Rev. Proc. Should we assume that section 3.13 has been invalidated in the absence of any clear statement from the IRS?

Usually, "is mailed" refers to a postmark, not the day you drop it in the box.

Effen is correct. Sorry if I gave the impression that a partial distribution was permitted oost-NRA.

The plan may permit distribution if the employee is still working beyond NRA. Must be included in the plan document.

2015 instructions for Form 1099R: http://www.irs.gov/pub/irs-pdf/i1099r.pdf See the last paragraph on page 12.

is this a qualified plan? governmental plan?

To the original poster, note the important difference between a plan merger and a plan termination. In the former case, (generally) employee options do not arise; the word "transfer" is often used in this case, although it may not be the best choice of terminology. Could that be the situation you have?

Pardon my bluntness, but this is silly. In the context of the 5500, the various categories are pretty simple: "active" means "actively employed", and "separated" means "not actively employed". Please don't seek complexity when it's not needed.

https://www.law.cornell.edu/uscode/text/26/401 Click on "Notes" for historical information.

Ask the "others" for documentation, or sources.

The school division may have other problems. Likely, Lincoln is asking for information that will be used in marketing. The school division may (already) have a policy about providing personal information to outside vendors, and may be advised to have legal counsel review the request before responding. Especially concerning is the request for SSNs.

Exactly! Perhaps this is the tip of the iceberg?

Although no one replied to your question, do you have anything to share about what happened w/r/t this Reportable Event?

One possible route: prove (in writing) that the ER made the mistake. If the Payroll Manager won't acknowledge it, then take it up the line.