Mr. T

Glad to hear you are going to stop an illegal practice. Another injustice prevented, with the help of the A-team.

Sorry, but this kind of conversation really bugs me. Can we please stop trying to figure out ways to nickel and dime the lowest paid people in our society in order to save the people who need it least? Take your creative energy and try to figure out a way to explain to the owner why this is a bad idea. If the plan pays the fee it is spread among everyone. It doesn't really "cost" the owner very much to let the plan cover the fee. I know the DC world charges participants for everything, but you have to see this is bad practice. People with the smallest account balances, who need the money the most, get dinged constantly just to get it. Here Sally is $150 contribution for you - aren't I great. Oh, you spent $5 more on coffee this month, so your fired. Lets see, $100 to process your distribution, $10 to prepare the 1099, $2 to liquidate the account. Here is your check for $38. Now be a doll and bring me my new driver before you leave. P.S. Peter - no disrespect to you intended. I think your idea would probably be fine, assuming it can still pass the non-discrimination rules, but consider how is the really different than just letting the plan pay the fee. Granted, it is $100 that stays in the plan that otherwise would have been paid to the slacker who got canned, but it isn't really $100 back into Big Wigs pocket.

How about, "Is you married?".

If things are so bad, he can always lower his accrual. It may not help for the year in question, but it would certainly avoid the problem in the future. I doubt the gateway he is giving to the employees is more than the value of his increased db accrual, plus the ps he is giving himself, based on his current comp. Sorry, I still aint got no pity for da fool.

Sounds to me like the "nefarious intent" is on the part of the owner taking a benefit based on a high past comp and then complaining because he has to give a few clams to his employees. Maybe they should look us up to see if there are any other wrongs we can help with. He's been earning a much higher benefit than his current comp will support, therefore, he needs to satisfy the gateway. This is one of those things the rules are designed to slow down. So I wouldn't call it a "mistake in the code" - its purpose is fairly clear.

You agree wit me? I don't even know what you talk'n bout... What does this all this gibber jabber mean?

What you talk'n 'bout fool! Dat sounds like an insurance salesman talk and Hannibal know I don't like no insurance salemen.

Really? What you think would be easier or more "abbreviated" than an email?

Hewitt and other national firms were/are going to companies and re-filing past SB and shifting contributions for the sole purpose of re-filing PBGC forms and asking for refunded premiums, of which they were/are charging a percentage (30% or so). Many other national firms complained to the PBGCs who said they couldn't do anything to stop it as long as the IRS permitted the re-filing of SBs. The IRS said, we don't care what you do. And this was the result. Personally, I hate to see Hewitt and others resort to this kind of ambulance chasing, but I am not upset the PBGC stepped to try to stop it. Also, Hannibal told me the IRS and possibly Joint Board are also looking at this so see if they have any issues. I hear actuares aint allowed to be paid on a percentage of recovery.

I'll add a "pidy da fool" when I see a fool worthy of pidy. Right now, I don't see one, cept maybe your client. Oh, by the way, thank you for your service as a scout and your good service to this board. We need more people like you in this place.

I don't want to hear no jibber jabber about ignorance. If they say they gonna do the distribution forms, then they should be held accountable. Why you makin that nice client pay for someone else's bad work. You should make those guys pay to clean up this mess. Then again, if the relative value were all close to 100% and the lump sum included the value of the early retirement subsidy so that they weren't rippen nobody off without telling them, then they might want to say "go forth and sin no more". But if that lump sum didn't include the subsidy and they wasn't tellin nobody, then we gots a problem that probably needs fixin.