Guest vrp Posted June 13, 2001 Posted June 13, 2001 As a TPA we have been asked to commingle assets of a 403(B) and a Money Purchase Pension and recordkeep as one plan. We have the ability to establish separate sources of money for reporting purposes. However, we are not sure if we can legally hold assets for both plans under one custodial account.
Carol V. Calhoun Posted June 13, 2001 Posted June 13, 2001 Here's a copy of the ruling Everett mentioned, in case you need it: Employee benefits legal resource site The opinions of my postings are my own and do not necessarily represent my law firm's position, strategies, or opinions. The contents of my postings are offered for informational purposes only and should not be construed as legal advice. A visit to this board or an exchange of information through this board does not create an attorney-client relationship. You should consult directly with an attorney for individual advice regarding your particular situation. I am not your lawyer under any circumstances.
Guest Tom Geer Posted June 15, 2001 Posted June 15, 2001 You have to remember that if you want to follow PLR 9540061, you have two hurdles to jump. First, unless the sponsor is eligible to have a retirement income account under 403(B)(9), the structure will have to be Trust A under qualified plan, with Custodial Account A, Custodial Account B, and comingled Custodial Account AB. Also, this does not make it a single plan for administration purposes, including 5500, audit, etc.
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