Renee H

Thank you. That's good to know!

I have a take-over 401k plan and discovered form 8955-SSA was not filed for 1 participant who terminated in 2013. She turned 70.5 in 2019 and has not taken any RMDs. All accounts are earmarked and this participant has had full disclosure and control regarding the investment of her benefits. Should I file the 8955-SSA for 2020? The record-keeper missed the RMD deadline. I would appreciate some advice on how to fix these issues.

Thank you for your responses. I was thinking along the same lines of not charging for the restatement since it is not the Plan Sponsors fault the current document is not available.

We are using Datair for our Cycle 3 plan documents. They advised us they should become available by end of March but I'm not sure I trust that timeline. What do I do with new 401k plans effective 1-1-21? Draft using the old document, then restate next year? Seems unfair for the company to spend the extra money on 2 documents a year apart. Is there any way around this? My answer may lie with the investment firm handling the investments but I am wondering what others are doing in this situation?