TPAMan

We found it easiest to stop using the messaging module by deleting any messages we had set up. There is too little control over when and how messages are sent out. Oddly enough, we have been communicating fairly effectively with our clients for many years and are resorting to what we have always done - personal phone calls, memos or emails.

Generally, it is considered a permissable plan expense.

Did the client sign as both Plan Administrator and Plan Sponsor or just Plan Sponsor. My understanding is that if they only sign in one place, it should be as Plan Administrator.

That is an alternative. Downside is the data push doesn't populate the First and Last Name fields in Web Client. Thanks for the suggestion.

We are just trying to get the hang of using Web Client. It seems when we set up a new client, they automatically receive an an email notification with their UserID and password. Then when we publish their 5500, they once again receive the same email notification with UserID and password. Is there any way to circumvent these duplicate nofications? (A fellow employee is submitting an incident to Relius; we are trying to see who gets an answer first.)

From what you have shared it appears that the medical bills were paid in full. We typically would be very hestitant to extend any Safe Harbor Hardship provision to credit card payments.

The only way to correct this is for the participant to return the proceeds he received from the 'forged' check and have the plan/trust reissue it as a taxable distribution to the participant. I know of no other way to remedy a seemingly fraudulent activity.

I would be surprised if the plan's trust provisions would extend the powers of plan restatement to the trustee(s).

When we have an inquisitive participant on our hands, we will typically ask them to prepare a written request for the information they want and submit it to both the Plan Sponsor and us (the TPA). We can then discuss with the Plan Sponsor how best to handle the answers. Generally, the participant never makes the written request - too much work I guess.

Recently we had a similar situation arise. We advised the PA to have the pending Alternate Payee sign off on the distribution/loan and this was then done with minimal duress.

Unless you want to be the one who decides which sources the QDRO is to be funded from, I would suggest a pro-rata allocation. As long as the Plan Doc provides for "early" distributions for QDROs, there should be no source issues.

The Corbel VS documents have language that allow for 100% vesting for affected participants in a partial plan termination. I view the "20% threshold" as the point where 100% vesting may be required, but in the instance where a distinct operating entity closes down, regardless of the percent of impacted particiapnts, 100% vesting should be allowable, if not the preferred course of action.

Isn't this the answer? Pro rata... across participant current source/fund balances? There should be no vesting or other issues. It is an earnings allocation.

If 6 more inquiring minds reply to your post, we may discover the answer!

This reminds me of a humorous argument I once heard about the human thumb. In and of itself, the thumb has pretty limited utility. In fact, by itself the thumb has so little use, we would probably be better off without them it was argued. Off with their thumbs I say! We are being funny aren't we George?

I have a feeling there are no regulations restricting the timing of rollover contributions.

I say have the plan sponsor amend the plan to add 'sham terminations' as a distributable event and then the whole thing becomes quite legitimate.

I can't think of a situation where a mutual fund (registered investment company) held as a plan asset would need to have an EIN reported. Now if your 'mutual fund' is really a common/collective trust, then the answer is 'yes' on the Schedule D.

Your posted Employer Contribution amount will be $60k less than the actual allocation to the participants.

We use the participant's total compensation, but any profit sharing allocation is offset by the participant's Davis-Bacon contributions.

I always thought they used it as a proxy for possible partial plan terminations.

Unfortunately for the daughter, it looks like the parents were spending her inheritance! Would be a rare case for the daughter to cause the spouse/estate to repay the Plan for the outstanding loan.

I have always used the most recent form available, which in your case would be the 2008 5500 forms. I believe you aer required to file the final 5500 within 7 months of the final distribution which means that the 2009 fomrs may not even be available in time.