Guest sue1jeff Posted October 10, 2004 Posted October 10, 2004 in 1998 db transferred assets to dc rather than give distribution options to participants. dc now has annuity options that were in db. to correct is it necessary to do vcp or can we just self correct? also if we do vcp can we distribut assets to [participants like we were suppose to before vcp approval? thanks
david rigby Posted October 11, 2004 Posted October 11, 2004 No expert on VCP or Rev. Proc. 2003-44, I'm not sure this transaction would be recognized; the IRS may consider that the DB plan still exists. In this context, does "transfer" mean the same as "merger"? Need competent ERISA attorney. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
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