SEP to 401(k)

[Guest bac]

Have an employee who wants to roll SEP into 401k. 401k allows for this rollover.

Does the SEP rollover have to be separately tracked? Once rolled, is it eligible for participant loans, since plan allows for loans using rollover source?

[Appleby]

No. The SEP assets are not required to be tracked separately.

The amount may be used for loan purposes

See revenue ruling 2004-12 ( attached) for the treatment of rollover assets to a QP

rr_04_12.pdf

[Guest philc]

Should track them separately. 100% vested. Different w/d rules may apply to the rollovers vs. other contribution sources in the plan. 401(k) Document probably requires they be separate. Allowed for loans provided documents don't prohibit it.