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Posted

I have a plan that has three locations, with lots of turnover. We (the record-keeper) did a force-out of an account that was less than $5000. When the person received the check, he questioned it. It turns out that he was re-employed with another location.

Fortunately, he did not cash the check, and we just reinsted the account.

UNfortunately, there were several other people in the same situation who cashed their checks.

What are the ramifications to the plan/participants if the money is not returnded to the plan? What if someone spent the money and refuses to pay it back?

I guessing it's an operational defect, but I don't know what the plan would have to do to correct it (besides having the participants pay back the proceeds).

Remember: two wrongs don't make a right, but three rights make a left.

Posted

Were the terminations bona fide terminations, even though they were re-employed? If so, I don't think there is a problem. On the other hand, if they were transfers within the organization, that is a problem (I don't know the correct correction, though).

Posted

these people were terminated, but were then re-hired. no transfer was involved. however, the distributions were done after they were rehired.

Remember: two wrongs don't make a right, but three rights make a left.

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