SFSD

Some participants statements have something saying to the effect that you need to notify us if something is wrong and if you don't we won't go back further than "X" period of time to make a correction. Yes, I know this doesn't address the proper correction method but it could be something to consider in deciding how far to go back. Four years sounds unreasonable, but . . . .

We use Broadridge and find they are less than receptive to reqests for changes in fund fact sheets.

Saw the blurb in Friday's BenefitsLink and looked at their web site, a company called Custodia Financial. Does anyone know how this product works and what exactly it is? Just curious. Web site didn't have any details.

Why does the participant have two separate accounts? Or are you referring to multiple "buckets" in a single account such as for deferrals, match, Roth, discretionary profit sharing, etc.

Do you spend/waste a lot of time looking for benefits at an individual's request that have long been paid out?? Had this happen for a benefit we finally found was paid out over 15 years ago. EE didn't believe it and wanted a copy of the cashed check which wasn't available after all this time.

I've always thought life insurance or annuity cash surrender values were considered a plan asset. Am I missing something here??

Life insurance cash values are considered plan assets and should have been reported on 5500's.

Thanks to all who replied!! BG5150 - No worries. Not buying a TPA! I'm a very old hand at this crazy business and trying to help someone who has just joined our company. It's been so long since I studied for designations! Glad those days are over.

My 2 cents - Aspect of business is TPA oriented. Good questions!! David Rigby - I still have those same two books!! Thanks for the reminder.

Does any one have a recommendation? The only one I have is so old I'm looking for something more current for someone just getting into the business.

Vesting stays as is as of termination date and amendment does not affect it. EE has to be an employee when plan is amended.

Technically speaking, no, the ER cannot get to the plan assets. However, I have heard of the EE and EE agreeing to the EE requesting a routine cash distribution. When the EE gets the check, she is supposed to go to the bank with the ER to cash it and they take it from there. If the EE doesn't want to repay this way, ER is out of luck.

Dave, thanks for bringing up this topic. I've been in this crazy business for over 30 years and my friends are always a great resource when I want to get an unofficial opinion outside the company where I work. I too was lucky to have a mentor when I started in the business and we kept in touch even after we no longer were working together. I was fortunate enough to have an opportunity to mentor a younger colleage and like to feel I contributed to her success. Haven't heard from her in years. The up and comers are smart and most are hard working too. However, it often feels like there is too much "pushing the buttons" rather than willingness to think through the issues. While that can make things more efficient, it often feels like we're removed from the process. My way of doing a restatement was to take the opportunity to see what might improve the plan design for the client/participants. Now we do it electronically by mapping the old provisions to the new version of the document. We seniors often wonder what this business will be like once all of us "gray hairs" have ridden into the sunset. Different for sure. I've worked primarily in bank trust departments and some in TPA's but it's interesting my experience is similar to yours as attorneys.

Lou - You are right. The target date funds are a series of funds based on retirement age. Bird - What was I thinking?!?!? I totally agree. If a person will be age 65 say in 2040, that's not going to change. Maybe it was too late in the day? Too much year end stress? Thanks to both of you!

Hope you can help a debate we are having . . . . As a participant ages and would fall into different target date funds, does all of his money move into the current appropriate fund? Or does the "old" money stay where it is and only the "new" money goes into the "updated fund?" It would make sense that all of a participant's money would be in the same current appropriate fund based on age. Even if the target date fund is elected rather than a default, would the funds move based on attained age? Thanks!

Believe you mentioned you do not know who was paying the premiums on the life insurance. Assuming it was indeed a plan asset, the plan should have been paying them and debiting the payments to the participant's account. The plan trustee(s) should have been both the owner and beneficiary of the policy. If the employer claimed the proceeds, it's possible the policy was purchased by the employer who named itself as owner and beneficiary. It isn't all that unusual for insurance to be used for business purposes. You need to look into these questions. The insurance company home office should be able to help if necessary by providing a copy of the application for the insurance and copies of any ownership and/or beneficiary changes. Hope this helps.

Maybe I'm missing something, but why would the employer want to direct the Davis-Bacon money to the QDIA?

Any loss is usually made up by the party causing it. It's up to the party who caused the loss (if indeed there was one) to figure out how to do it. The calculation is not all that difficult to do and definitely should be done. Hopefully, there was no loss so restitution is not needed. Will leave your other questions for the legal experts to answer.

We would send the proxy information to the directed account participant and request he provide instructions on how to vote. We'd then execute the proxies as plan trustee and submit them. Kind of doubt signatures are checked on proxies, but if they were, participant is not the owner of the securities, the trustee of the plan is.

Carefully consider resignation. Do you really want this client? If you decide you do, be sure to let them know the estimated fees to get the plan back into compliance. As to DFVCP, last I heard you can file unless the plan is under audit.

Do not rush into establishing a retirement plan! I've been doing this work for more years than I care to admit and can only "second the motion of the earlier posters" who recommended you take your time. It's important to work with someone who is into the administrative aspects of retirement plans, not just the investments. Be careful and don't enter into any contracts you don't fully understand. Good luck. You will be glad you took the time to chose carefully. Moving a plan is expensive and a lot of work too.

Dave, We all want to see the missing attachment. Can you post it again?

I guess another question is did they purchase the actual Canadian coins? Are they held by a custodian? Or did they purchase "an investment" that's not the actual physical coins?

katieinny - maybe you don't want this one after all?

You need to get to the right person at the insurance company. Try for a department that may be named "Policy Title" or "Pension Department." If you get desperate, try Legal Department! I used to work in the insurance industry so can assure you someone knows what's going on. You just have to find that person/department. This does sound like a 403(b) plan. You might want to see if you can get a look at one of the policies. The application at the back should show who is the owner and that should be the Plan Trustee(s) as someone posted earlier.