Pam Shoup

I agree with David that you should ask for it. But in my experience, we rarely receive it from other providers. I recommend that you require all participants to re-enter their beneficiary data and remind them several times a year to update their beneficiaries. In the case we do receive beneficiary information from a provider, we keep the data on file. In the rare instance that someone passes away without a beneficiary, we look to the old file to see if anything is listed there.

I would add that reporting the correct participant counts is important. I have had some takeover plans where the counts on the 5500 were just under 120 to avoid the audit requirements when our review shows that the number of participants at EOY should definitely have been higher than what was reported.

Let me add one more thing, does the plan's 404a-5 notice disclose to the participants that the forfeitures will be used to pay plan expenses?

You should be able to do this via a Merger and Transfer Agreement whereby you merge and transfer the assets from the PEP to the stand alone plan. The PEP will report on its 5500 the transfer out, listing the name of the stand alone plan, the EIN and the Plan Number. You will need to review for anti-cutback issues, etc. Your plan document provider should have a model M&T available. The current PEP may also have a model you may be able to use. The stand alone plan will list the transfer in from the PEP on its 5500. The same would apply if you are going from PEP to PEP. A M&T will need to be prepared. I am not sure why this would be a mid year plan issue and why the PEP/RK would not permit the transfer out from a plan document or recordkeeping perspective, unless there was some agreement that it could only be done at PYE.

With the new Roth Catchup Rules for Highly Paid Individuals starting next year, I am trying to make sure that I understand the Rules for recharacterization. I understand that one of the methods for recharacterization is In Plan Roth Rollovers (if completed timely and the plan permits). My question is this: If a participant is under age 59.5, would this be done as an In Plan Roth Transfer and the 5-year recapture rule apply?

We agree with the answers above. We use ERISApedia as that meets our needs for most day to day research. For the super technical questions, we subscribe to the ERISApedia service where we can ask X number of technical questions per year and get a very detailed response. We have been looking at the AI and are thinking about it. We also like their (free) continuing education webinars, especially for our QKA/QPA and ERPA personnel as they are on a little higher level than classes we can take elsewhere. This saves us a lot of money in paying for CE credits for our credentialed personnel. We have also not had any issues with their classes meeting the ERPA requirements.

We use LifeStatus 360 for small jobs. You get results almost immediately and they reasonably priced. They also perform death index searches and obituary searches.

I agree with Ernie G and Peter Gulia. The Plan Administrator role is much more than just signing the Form 5500. The Plan Administrator is legally responsible and liable for the operation of the plan and is a fiduciary to the plan. If there were to be an IRS or DOL audit or review, the PA is the one who would be the hot seat, so to speak. Anyone who is taking on this role should be aware of their fiduciary responsibilities. Most service providers in our industry do not take on a fiduciary role with the plan and instead perform ministerial functions at the direction of the fiduciary. There are service providers who will take on the PA role and that will be clearly defined in any service agreement and most likely in the plan document. As far as other things that need to be done to change the Plan Administrator, I would look at your Plan Document and previous 5500s to determine if the company is named or an individual is named. You may need a change to the document and/or SPD. If an individual is named in the Plan Document and/or on previous 5500 forms, you may also need to file Form 8822-B with the IRS. As always, checking board minutes, etc. is always advisable. There should be something official that says who is authorized to act on behalf of the plan. These can become really important in the event of a fiduciary breach and any fidelity bond/fiduciary liability insurance the plan may have.

In the new FIS Retirement Platform (FRP), there will be no Crystal Reports. They are switching to ThoughtSpot. FIS is also anticipating that we will be writing APIs to get data out of the system into usable reports. If you are a Chief Technology Officer or someone who will be in the decision making chair for future software needs, you may want to check out www.rtug.org. This is a Recordkeeping Technology User's Group. This is a high level group of people well versed in IT and is not meant for the common Relius user. This group is currently exploring all options available.

Datair, FT Williams and ASC do not have a recordkeeping platform, so they won't be of any help for your recordkeeping needs. We used to do the plan testing in Datair and the recordkeeping in Relius. However, that got cost prohibitive and we ended up moving everything to Relius. No matter what we do as recordkeepers, it is going to get a lot more expensive to stay in this industry as an independent recordkeeper in the next few years.

The two major competitors that I know of are SS&C and Congruent for recordkeeping software. I would be interested to know if anyone knows of any other competitors.

I don't know if FIS knows the answer to that question. I recently attended a conference with the architects of FRP and they weren't even sure when the DC compliance piece was going to be added to FRP. The first generation of the software will have the recordkeeping only piece.

I recommend that you look at RVUG.org. This is a group that primarily uses Relius for recordkeeping. I would at least sign up as a free user. You will receive invitations to seminars about using Relius that are either free or low cost (something like $25 for the webinar). If you do a paid membership, you can access more information and ask questions, etc. To answer your question directly, every firm that I have spoken to uses Relius tools differently, with some using them extensively and some firms building tools outside of Relius to do a lot of tracking, etc. Please keep in mind that Relius will be sunsetting in the next few years and will be replaced by the FIS Retirement Platform (FRP). This takes the current FIS Omni software and adds some of the features in Relius to Omni. The decision makers at your company should be looking into the new platform and making some decisions about if you will migrate to that software or use a competitor and when you would be making the switch. It is not too early for them to start their decision-making process about the new software.

You should send a W-4R form with all of your distribution paperwork for nonperiodic payments so the participants can make their withholding election. The form explains when 10% and 20% are the default options and allows them to choose less than 10% for the applicable distributions or more than 20% for the applicable distribution types. The form also includes some basic tax calculators.

If you have SSN information, we suggest Life Status 360 for an affordable option for address searches. They have an address search, SSN death records search and obituary search options. We like them for our DB plans as we upload a file to them once a year and we receive daily reports of anyone that shows up in a state death report or an obituary. The records are then run through the Social Security Death Index and several other death index databases whenever they are updated. We oftentimes find out that someone is deceased before a family member contacts us. It really helps to keep our DB records up to date. We also use CLEAR from Thompson Reuters, but that is a more expensive option, but allows you to do next of kin searches. However, you don't necessarily need a SSN to search there, but it does help, especially if you have a common name.

We see this happen frequently where participants switch from union to non-union and vice-versa. The only hiccup it to make sure that the loan payment is being remitted to the recordkeeper and account/contract number that belongs to the non-union plan. The loan payment will also need to be edited from the payroll report from the union plan to make sure the loan payment is not remitted to that plan.

This is a discussion to have with the participant as they will need to complete the W-4R form prior to their distribution. The W-4R form could also help them to determine how much they may want to have the distribution grossed up, or at least give them a realistic picture of their potential taxes.

We have form letters that we wrote for both incoming and outgoing assets. We are gettlng lots of requests from fund holders for a qualification letter before they will issue rollover distributions or accept rollover distributions. We insert the plan name, participant name and the last four of the SSN into the qualification letter. For the incoming asset letter, we specify if the plan takes pre-tax money only or pre-tax + Roth deferrals. (Probably going to need to edit that part once we start seeing Roth employer money.) The letters are signed by the PA. We have not seen any pushback with the content of the letters, other than sometimes they complain that the letter says John Doe, versus John J. Doe. For our purposes, when we get an incoming rollover check, we look for a 5500 and check the feature codes to see if the plan intends to be a qualified plan.

Don't forget to check your plan's loan policy which will let you know if your plan permits more than one loan. It should also specify if loan re-financing is required, etc.

Does he have any rollover money in the plan? The plan may allow in-service distributions of rollover at any age.

As an open-architecture recordkeeper, we routinely prepare combined Sarbanes-Oxley/404a-5 notices and manage the fund change process for the advisors when plan wide fund changes are requested. We have not traditionally charged a fee to do this. Lately, advisors have been asking us how much we charge. Is this something you guys are seeing as a line item fee and if possible, can you share a range of how much a fee are you seeing?

Actually, the language he is referring to is in the model 402(f) notice: Unless you elect otherwise, a mandatory cashout of more than $1,000 (not including payments from a designated Roth account in the Plan) will be directly rolled over to an IRA chosen by the Plan administrator or the payor. A mandatory cashout is a payment from a plan to a participant made before age 62 (or normal retirement age, if later) and without consent, where the participant’s benefit does not exceed $5,000 (not including any amounts held under the plan as a result of a prior rollover made to the plan)

They sent out alerts on Friday that the ticketing system was down and then they said it was back. If you call, the phone rings and rings and then someone picks up and hangs up. Customer service is seriously lacking. I still have an issue pending from April of 2021 with app issues and vesting. I have an issue pending for several months now with MFA and the app. If a participant needs to enter a PIN to access the app, it just spins and spins. If they re-boot their phones, they can usually go into the app afterwards. Needless to say, we have received a lot of negative reviews by users of the app and there is nothing we can do about it, since we are not going to disable MFA. A lot of enhancements were promised for the app but it has been crickets on those since it launched. If there was a viable alternative, we would seriously consider switching.

It may be just a "paper" position in the plan and not actual assets. We have seen this problem when a plan has a "Worthless Investment" that shows up with the last avaiable value and someone tires to clear it from the plan, but doesn't do it correctly. I guess that I would check to see the type of investment that it is and if it is just a paper position, the Plan Administrator may need to do a form to totally clear it from the plan.

Check with PIMCO and see if they will permit you to liquidate the fund before the PUT has expired.