Mike Preston

That is the reason for the quote function.

Very nicely put.

Probably because the FERS plan is self-insured and the Met policy is, by definition, not. You also probably have administrative loads on the Met policy that are much lower than FERS allows. In short, comparing a retail product to a massive federal program is a fools errand.

I agree it should be however I'm not aware of any guidance that specifically exempts 401a26. Are you?the correction is the same sort of correction you would expect in order to avoid a 436 violation. That is, put money in the plan.

Yes. No. If I'm understanding.

Do what he said. For whatever year you filed with "final" indicated, amend it to show zero participants at the end of the year. Do not lose sleep.

No good deed goes unpunished.

".... should NOW be divided....."

Isn't the age 72 after 2021?

As always, agree with Bird.

It can't be ACP so it must be 401a4. I'd have to noodle a bit as to exactly how though.

Don't forget the 401a9 rules which limit the j&s % based on age difference.

I'll take the opposite position. Whether by amendment or administrative action, the participants were paid what they were entitled to after giving consideration to either the document or the policy. There is nothing to repay there is nothing to correct. And, in fact, if you are successful in getting money back from a payee, the plan has violated 411d6.

Am I the only one who questions the fact that the qdro needs to be amended? Something doesn't sound right.

Seems like a prohibited transaction to me.

Yes

Are we sure that there is no exception to the substantial and recurring requirement in the case where the plan sponsor has no pensionable earnings?

That determining actual rate of return is just a simple spreadsheet away. There always seem to be complications that make that determination time consuming. When that happens, which it seems to more often than not, the course of least resistance is to use the DOL calculator letting the client know that if the government or a participant complains they may owe a little more.

Not $400,000.

No negative numbers!

No negative numbers!

Not in my book. But i don't do qaca's or eaca's.

If you say so. That has not been my experience.

With interest rates as low as they are today why would you mess around with trying to exclude an earnings calculation which is likely to be pennies?

I tried I really tried. Failed. Is the above your definition of cofeffe?