MMMBENE2000

In some of our DB & DC multi-employer, qualified plans, we have sent applications out to surviving spouses and beneficiaries (for J&S survivor benefits on DB or distribution options on DCs, for example) and not received responses (nor returned mail). By the way, this question is applicable to participants and beneficiaries that are all under 70 1/2. To what extent must we pursue these situations? Send the app and just wait until the RMD rules kick in? Send a few regular reminders and then send a formal denial (based upon not submitting an app)? If this (under 70 1/2) pursuit is in the regs, can anyone give me the reference? Thanks!

In a multi-employer, qualified defined benefit plan, is it required that participants be notified that they have incurred a permanent break in service and have forfeited their accrued benefit? I've been told it's necessary by legal counsel because it gives the terminated participant time to dispute the loss of service and that the notice starts the "count" for the statute of limitations during which the dispute can be filed with the Plan. Without the notice being sent, then apparently the participant can dispute the issue decades later, which of course makes it harder for the Plan to defend the record. So, does anyone know if this notice is required based upon regulation or just good Plan practice for protection? If it is reg, I'd like to know where I can find the language outlining it.

Right! I was wondering planning to make a few modifications to our procedures and wanted to know what was required and where we have leeway, but still within good administrative practices. Thanks for the info - I appreciate your help! (Hey...I know an Actuary named Andy from Indy...!)

Is the Plan Sponsor of a Defined Benefit Plan required to notify participants when they've reached or surpassed Normal Retirement age (i.e. a letter reminding the Participant he/she is now eligible and should consider applying)? What about having reached/surpassed age 70 1/2? I'm looking for language regarding whether these notices are REQUIRED by any entity or if it is merely good practice. Thanks.

We are a TPA administering a 401k plan for a mutli-employer union. This union offers a DB, an employer-funded DC and an employee-funded 401k. Contributions for all of these plans, plus their healthcare, come into our office. So, we started reviewing the census to determine who should be reported on the SSA-8955. We discovered something that hadn't occurred to us before. We have a participant that stopped contributing to the 401k two years ago - thus appearing to be eligible for the SSA report, however, he continues to have hours of work for the union - receiving contributions for the other two pension plans. So, does he get reported on the SSA8955 for the 401k Plan or are the "hours of work" he's still performing for the union (but not contributing to the 401k plan) mean he hasn't really "separated"? My gut tells me he would still get reported because for the 401k plan, he HAS separated. Playing the devil's advocate...we could imagine a scenario where we ONLY administered this plan and some other TPA administers the other pension plans and thus we would never have known about the continuing work hours. Opinions?

Hi all, We administer several multi-employer trust funds - defined contribution plans, usually with only employer contributions (although some of the plans allow employee pre-tax contributions). We've had our first request to take a distribution from one of our DC plans and roll it over to a Roth IRA. Unfortunately, we've never dealt with this before. Can you tell me exactly what we have to do (if anything) that is different from a rollover to a traditional IRA? For instance - do we have to tax the distribution? What about the 1099r coding - is it still just a "G" or is there a special code for rollover to Roth? Anything else I'm missing? Seriously - I need A - Z instruction. Please help! Thanks so much!!

Do the 415 limits apply to ancillary benefits from a multi-employer qualified DB pension plan, like a monthly disability?