Bill Presson

Notifying as a practical matter would almost assuredly be done. Especially to those participants with account balances since they'll be receiving distribution paperwork. But I believe the thrust of the OP is whether is was required which would trigger meeting certain deadlines, etc.

The assets of the plan are owned by the trust and the trust typically has it's own TIN unless the assets are held by a formal recordkeeper. That's the TIN you need to be locating.

I can't believe this thread has two pages.

If you look at the link I provided from 2004, they (at least some of them) reached the conclusion that a former participant with no entitlement to current or future benefits was not required to receive an SAR.

I can't imagine that an active participant without a balance wouldn't be entitled to a copy of the SAR. How that person would be carved out of "participant" would be interesting. Prior BenefitsLink discussion:

Generally if the insurance company sends you the Schedule A, you need to include it.

Yes ma'am. For what other reason (perhaps plan document?) are you concerned about using the EIN for?

If the original plan sponsor is still the plan sponsor and the spin off is a participating employer, then the 5500 would still reflect the original plan sponsor's ID. The participating employer would be listed on the 5500 MEP attachment.

The sponsor's ID I'm assuming hasn't changed. For plans being reported on a 5500, the sponsor's ID and the plan number (eg 001, 002, etc) are the numbers shown on the 5500. For a multiple employer plan, the lead sponsors TIN is typically the one used for the 5500. A plan's trust often, but not always, obtains TIN to show the ownership of the assets. Very rarely does a plan actually get a TIN. In fact, I've been doing retirement plan consulting for more than 30 years and never had a plan need one.

Welcome aboard, Ms Ilene.

How can this not be accurate? [rolls eyes so hard]

I don't see how this is an insurance issue. If he keeps working and has earned income, I'm not aware of anything keeping him from contributing to a qualified plan.

I don't see how it's a tax deferred event. Nothing was withheld from their pay before tax. It's no different (I don't think) from a participant writing checks to pay for COBRA coverage.

Maybe I'm missing something, but since it didn't go through payroll, why would 1-3 even be considered?

Correct, it's determined on the first day of the plan year. For a new plan, though, if there are more than 100 participants, it needs an audit. The 80/120 rule doesn't apply.

Any reason not to change the eligibility to 90 days and add the auto enroll?

Happy birthday, Dave!

Congratulations, Mike!!

We're a bit of a mix because we've acquired 6 additional firms in a little over two years. So, every office works somewhat differently. We plan to be a hybrid where an administrator will be responsible for almost everything. They might also have an assigned assistant if their case load is large enough. We have several shared assistants too. We do plan to carve out onboarding of new clients, trust accounting and an optional distribution dept for employers that elect. We outsource our IT and then have a few other specific people like our CEO, me, our business manager and director of marketing. Most of the former owners (as well as some new hires) are providing client relationship/business development services. But it's working well now and we know where we're heading. That was the biggest struggle, but is now making things easier.

It's like the first hint that Christmas is coming! :)

Auditors are required to become comfortable with the plan and assets for time periods prior to the beginning of the audit. So they will typically review the plan back a few years to make sure they can report the numbers properly. If you are the auditor for the plan, your firm should have established practices or contact the Employee Benefit Plan Audit Quality Center if you need additional direction.

Ha!

Smith Barney has been gone for several years now.

Yeah, I miss not seeing who admired my comments. :)

Ha! I meant "about". Edited mine so I don't look so terribly stupid.