Rich Hudson

What you likely have is a DRO - if this is asking the 401(k) plan to split your account but you have already rolled it over to an IRA then the Plan will not qualify the DRO since they no longer have access to your money. When the DRO is rejected by the plan the attorneys will need to fix it. At that time your attorney and your exes attorney should take more care in drafting the DRO to be sure it correctly splits the account in the manner agreed to during the divorce settlement.

The LIS serve the purpose of letting participants know about how much life time income they would receive if they wanted to purchase an annuity. The LIS is only required annually. So, if you are providing monthly or quarterly statements then one of these needs to include this additional information. We have been getting several requests to help out administrators with the calculation of these amounts to be reported on the statement.

I am not sure what the constraints are that you are using to determine how to amend the pay credits up or down each year. But typically if they can be articulated you can just have the plan auto adjust the pay credits up or down each year rather than having to amend the plan. This is what is done in variable / adjustable accrual rate plans and the logic can be used to adjust the pay credits in a cash balance plan as well.