K2retire

We've had many clients get this message because they registered as a "filing author" instead of a "filing signer" with the DOL.

That is correct.

I've heard of several TPA firms that routinely require it on balances over $5,000 so that their processing staff doesn't have to determine whether or not the plan (or part of the plan) is subject to QJSA rules each time the process a distribution.

Monday through Wednesday of this week the EFAST hotline number was going directly to a recording saying that the call could not be completed at this time. It sounds like the EBSA may have underestimated the capacity they would need to handle the new process.

The DOL will show returns on the website even if they are submitted with no signature.

Does the breach occur when the annuity is not purchased (and how do you determine the date that something didn't happen?) or when the claim for benefits is denied?

You guys make sports sound fun!

Or you can just ignore it and continue with the submission.

It apperas on every plan we have published. Ignore it.

Different firms use different titles. You need to get a job description to have a clue what they mean by the title. Salaries vary widely even within the same geographic area.

You only deduct half of the self employment tax.

As a TPA, our ERISA attorney advised that the corporate bankruptcy trustee does have the power to appoint a plan trustee, but does not automatically become the plan trustee without such an appointment.

The client may not care, but you and the boss should be discussing the potential liability to your firm for facilitating tax fraud. I doubt that your boss is willing to risk jail time for this client, but if he/she is, you might want to polish up your resume.

Haven't seen it with Hancock. But Hartford sales people have been telling our clients that they have to move because we're going out of business.

Non profits don't pay income tax so there's no deduction anyway.

We've been having the same issue since early last week. Relius is working on it, but we haven't heard an anticipated date when it will be fixed.

I agree with Jim. But that may not produce the exact same result described in the original post. For example, someone who had only 2 YOS with the previous employer would not be 100% vested.

We usually advise our clients not to provide the distribution paperwork until the final employer contributions are deposited for the year. Then they can initiate a force out at any time after 30 days of sending the paperwork, provided it is not delayed until more than 180 days following the sending of the paperwork.

The timing for distribution processing is governed by the terms of the plan and the limitations of the underlying investments. You should be able to find more information in the Summary Plan Description.

It is usually standard procedure to make a payment during 2008 based on the 12-31-2007 account balance in an annually valued plan. Have they given any basis for the request for repayment, such as the plan calling for distribution after the end of the plan year of termination?

That does not cure the problem of not being able to publish more than one form.

And as far as all procrastinating clients are concerned, we will be personally responsible for the DOL's failings!

So far we've only heard of one out of about 8,000 plans.

The acknowledgement number only applies if it was filed electronically using EFAST.

We've had the same problem and been told to wait. We had hoped to publish the final 2010s for terminated plans along with the 2009s.