TPApril

Thanks for your response. I would make a correction to my first post - regarding defaulted Loan 1 - interest, as calculated from date of last payment to date of default, was indeed included in the 1099 in 2005. So I think no interest on that loan is taxable at this point (since interest calc'ed later is only used for future loan availability calcs).

Participant has terminated and has two outstanding loans – the first one defaulted in 2005 and was a deemed distribution with 1099 issued; second one is active loan until termination. Participant is taking cashout, so I’m trying to calculate both withholding amount and distributable amount after loan offset of second. This is my calculation, any helpful thoughts? General Account Balance (excluding loans) $50,000 Loan 1 - Defaulted with 1099 in 2005 $20,000 Loan 2 - Active Loan Current Principal $15,000 Interest on loan 1 accrued through default date (never paid or reported) $500 Interest on loan 2 accrued from last pmt to distribution date (never actually pd) $100 Subtract Loan 1 with phantom interest - already deemed $(20,500) Total - Taxable Amount $65,100 Less 20% $(13,020) Offset - Subtract Loan 2 with interest $(15,100) Net Cashout Amount $36,980

I'm curious to know how this turned out?

Does anyone know off hand if Wells Fargo Advisors, formerly Wachovia, but now owned by Wells Fargo, can certify investments to allow for a limited scope audit, or someone I can contact there who can actually answer that question for me?

Well I feel naive posting this question, but I had thought that the final regs for 408(b)(2) had been published and we are now working towards putting them into effect by 1/1/12. I was recently told by attorneys that the final regs are not out yet. I did a quick search and found the Federal Register publication dated 7/16/10 entitled 'Interim Final Rule'. I was thinking a best practice would be to get started with these rules. As an industry are we on hold waiting for additional rules prior to 1/1/12 and we should wait before revising our contracts?

Have you figured out what you are planning to do, or have you done it already?

We are in the process of putting together software/subscription requirements for a new TPA practice. Coming from a large firm, we had an inhouse daily research on current topics. Not having access to that anymore, We have found a variety of free daily or weekly newsletters such as 401khelpcenter, freeersia, benefitslink, etc. CCH has a free subscription and a pay subscription. What is the general consensus on sufficient digest/updates to provide necessary goings on for a tpa practice? are the free resources sufficient?