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  1. I'm requesting input from the daily plan administration community. We are trying to minimize risk and not tak on too much fiduciary responsibility in our actions. In our practice as a daily record keeper we direct the trade orders. Some in our firm would like a client affirmation prior to processing ADP corrective returns. Others know practically, involving the client or participants in this process is a frustrating process that only creates anxiety and has its own monetary risks and service problems. What are others doing? Processing without approval? Explaining the process upfront and not asking approval at the time of processing? Asking for approval and processing after a # of days regardless? Asking for approval and not processing until approval is received even at the risk at missing the corrective distribution deadline?
  2. Saw the following today - this could, if it is made reasonably user-friendly, be very good news in that a terminating DC plan with lost participants should presumably be able to transfer the funds to the PBGC. I've been waiting for this! I wondered if anyone had heard as to whether the DOL will be coordinating with the PBGC to deem such transfer as an appropriate fiduciary decision with a liability shield? The Pension Benefit Guaranty Corporation (PBGC) has released its semiannual regulatory agenda for Fall 2012, which outlines regulations that have been selected for amendment during the next year. Proposed rule stage Among the items in the PBGC’s proposed rule stage are: • Proposed amendments that would amend the PBGC’s regulation on Reportable Events and Certain Other Notification Requirements (part 4043) to conform to changes under the Pension Protection Act of 2006 (PPA; P.L. 109-280) and the PBGC’s regulations on Premium Rates (part 4006). • A proposed rule to implement section 410 of the PPA, which allows certain terminating plans not covered by the existing Missing Participants program to participate in that program.
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