Participant paid from wrong plan in Master Trust

[Guest gerry326]

We have 4 DB Plans contained within a Master Trust. In the annual census submission, I realized that we set up a participant who retired 8/1/03 incorrectly on our bank's system, and he has been paid out of the wrong plan since he retired. I know we need to transfer the assets and calculate earnings/losses associated with those assets. Do we need to do any DOL or IRS filings?

[RCK]

I'd vote "no"on any filings.

This is not a prohibited transaction because it is between two plans, not a plan and the sponsor. So I'd transfer funds in such a way to make both plans whole, including making sure that the reimbursement to the first plan is coded as a negative benefit payment. I'd document the transaction in my files, including the interest calculation, and call it good.

RCK

[E as in ERISA]

Does each plan have its own assets and the benefits were taken from the wrong pot. Or is it a group trust with commingled assets and the transaction was merely recorded on the wrong plan's records?

[Guest gerry326]

The funds are in a comingled Trust, so it seems to boil down to an accounting error. What we are considering doing is:

- leave the money that should have been paid to the retiree in the Plan he should have been paid from and

- add back the amount paid incorrectly from the other Plan plus earnings

We are also going to run all of this by our auditors before they start the 2004 Plan Year audit.