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CRBarnard

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  1. I have a plan that terminated and 2020 is the last plan year. It’s a short plan year. Do you have to file a Form 8955-SSA to report the short plan year as the final year even if there is no one to report on the form? It appears that there is a penalty if you don’t report the plan termination. I see no actual field to report that information on the Form SSA. Following is from the penalty section of the Form SSA instructions: “In the case of a failure to file a notification of a change in the status of the plan (such as a change in the plan name or a termination of the plan), or a change in the name or address of the plan administrator, section 6652(d)(2) imposes a penalty of $10 for each day during which such failure occurs. The penalty, up to a maximum of $10,000, is imposed on the person failing to so file unless it is shown the failure is due to reasonable cause.” Any clarification here is appreciated.
  2. Thanks for this information and the webcast link. This is very helpful.
  3. We have a former participant who left our client for non-COVID-19 related reasons and started working for another employer. That employer just laid her off. Can she now seek a distribution from her former employer's plan because she's been laid off from her current employer?
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