JanetM

AndyH I chucked at the ending too. You are right, very important stuff going on in Crawford today. Note I fixed date in previous post. Q What about this afternoon? You said there will be something more this afternoon? MR. SNOW: I believe there will be hundred degree club activities later in the afternoon. Q I see, not some presidential appearance that we're going to be summoned to? MR. SNOW: Not that I'm aware of. Q Will you report back to us -- MR. SNOW: If you are summoned, we will make sure that you are duly informed. Q We'll expect a full report on the hundred degree club.

Hmm, soon means in the near future. Since he started 10 day vacation on August 3 guess he won't get to it till he gets back to Washington. That means some time next week.

The 100 count is as of the beginning of the year. 29 C.F.R. §2520.104-46

You are stuck on this one since you have permanently ceased obligation to contribute to the plan. Are you by chance in one of the groups that have some exceptions? Building and construction Trucking Household goods moving Public warehousing Retail food Certain segments of the entertainment industry

Am thinking you will have a nightmare tracking the 180 days for appeals. You have to notify the participants of a denial and then the clock starts. Don't even go down that road is my opinion. Does the TPA have provision for participants to sign up to get their stuff online?

Right, to merge in 2006 will lose safe harbor status. You would have to do it on 1/01/07 and pick single formula for everyone. Tom, if the are safe harbor don't they get ADP free pass and just have to satisfy ACP if there is after tax contributions?

Transition rules allow you to test the plans separateley until 12/31/07 - an guessing the plans are 12/31 year end. So with that said, you could keep the two plans place and merge anytime in 2007. After 1/01/08 you will have to aggregate the two groups for testing. To merge the plans you will have to settle on single formula due to uniform allocation rule.

It is more like just stopping payment on the check, since the funds haven't left the trust. If the participant cashed the check they are stuck with it.

PiP we only do this if the time is extremely short, not if the participant has been holding the check. If someone makes a mistake on website and calls in day or so we can void the transaction and stop the check.

I don't see the harm in reversing the distribution, as long as the participant hasn't cashed the check. We have done this with loans and hardships when participant decides they don't want/need the funds and they return the check uncashed.

SoCalActuary, wouldn't you also get the SSA and maybe IRS on this. Just wondering since the P and SSA will not be part of mandatory electronic filing in 2008. EBSA doesn't deal with these forms.

kjcurly, are you TPA or employer? Am wondering who made the mistake? Did TPA make the mistake? Did employer give TPA bad data? Who ever made the mistake should be the one to make the participant whole, that means filing amended returns.

Sounds like hardship withdrawal to me. Also sounds like it was done properly and was indeed a distribution. Due to the fact tax was withheld, it could not have been loan check.

I would just write the .02 off. The cost in administration, check fees, 1099 and such stuff far exceeds the .02.

Your 2005 beginning balance has to match your 2004 ending balance. First, double check the assets at 12/31/04 to make sure you have a problem. File an amended 2004 5500, no explanation necessary. File your 5500 for 2005 . Yes, you expenses should be deducted from your assets to get to ending balance. Find a statement from the custodian of the assets to verify the amounts.

CCHs Plan Termination Answer Book has chapter on spin offs.

The number is total reported on the SSA, includes all the codes.

Not sure I understand. Do you mean the final short year in which the assets and liabilities of the plan are transferred to the PBGC? I don't know of any exeption.

I second the no.

Effen, The company I work for sponsors 13 DB plans (down from 30+ due to mergers). I have been authorized by the Retirement Board to sign as plan administrator/sponsor. I enter the basic plan data, the acutuaries add their part after an in house review, they post to site and I review. Then I tell the Trustee how much to wire and "sign and send" PBGC forms.

I am the plan sponsor and filing coordinator. It is easier for us this way as have three actuarial firms who do work for us. Works great. I entered all the plans, actuaries were assigned and they did their part, I "signed" and sent the forms in.

AndyH, I have had only one experience like this. I am the plan sponsor and I mixed up the amounts for two DB plans. PBGC caught it three years later. Mixed up 20K and 1K. PBGC wanted lots in penalty and interest. When I explained they had the money but I identified the two plans wrong they waived everything and reposted the amount to the proper plans.

Have done a couple of these and have only used 5500 and 5300 to report the amounts. The Trustee never reported the amount in any form.

Not so fast. You can, but it is not easy. As long as you can pass coverage, BRF test, and non dicrimination testing you could split the group. With all the hurdles it doesn't make a whole lot of sense to do this. What is the purpose of doing this? What benefit does the one group get that the other does not?

Hi Dave, I vote for the banner ads too. Thanks for asking!