Distribution of contributions deposited after account balance is distributed.

[Guest mmc]

One of our daily valuation plans provides for immediate distribution. The plan also deposits its matching contribution in September following year end. So, participants who terminated in 2004 will receive their matching contribution in September 2005.

If a participant had an account balance >$5k and the match deposited for 2004 will be less than $1,000, can the trustee cash out that balance, or do you always look to the original vested balance?

Also, how long do you honor distribution papework submitted by the participant? If a participant originally elected a rollover in 2004, is that election valid in September 2005 once the matching contribution is deposited, or must we get another form completed?

Our other concern with some of the distributions that occurred in early 2004 is that the terminated participant has possibly closed that IRA account.

[E as in ERISA]

There was previously a lookback requirement, but the 2000 411(a)(11) and 417 regulations eliminated it.

All eligible rollover distributions require a 402(f) notice (with 30 to 90 day requirements).