Schedule SSA for 2004

[Guest RayBerry]

There is an issue as to whether or not the 2004 Form 5500 instructions changed the rules for completing the Schedule SSA. Apparantly in the past, it was not required to enter a vested termination with a D code (delte) after he was paid out. (It was probably very prudent to do so to avoid trying to prove to the participant he was paid out in the past after he has received his letter from the SSA.) Also, apparantly many plan sponsors did not bother to delete participants that were later paid out.

The wording in the instrutions has changed slightly. Do the instructions now require that if a participant previously reported on the Schedule SSA is subsequently paid out, the participant MUST be listed with a D code on the 2004 Schedule SSA? If so, does this apply retoractively, that is, for a plan sponsor who has never used the D code, must they add to the 2004 Schedule SSA with a D code all participants subsequently paid out since 1976? Is there any offcial or unofficial guidence from the DoL?

[Harwood]

http://www.corbel.com/news/technicalupdates.asp?ID=303&T=P

[JanetM]

I don't see it applying retro to prior years. If there is no way to come up with previous years distributions then just skip it. Going forward it would be easy to keep list of who has been reported.

I have so many take over plans (am plan sponsor not TPA) that I just now list all distrbutions as Ds on SSA if they terminated before we bought their company.

[AndyH]

That change looks like as close as the government can get to imposing an "unfunded mandate" upon itself. How is the un-reporting requirement ever going to be enforced? Are they going to start imposing a new penalty each year for failing to "un-report" somebody?

And, while venting on this subject, how about the requirement that an employer has to report participants names "as they appear on the social security card". How many TPAs out there request copies of social security cards when completing SSAs? Are IRS auditors going to start cross referencing SSAs to social security cards?

Some goofballs are making these decisions and we are paying their salaries, IMHO.

Boy, that feels better.

p.s. My next related vent will coincide with adding 250 vested terms to the SSA form that allows for 4 participants. Subsidy for the Post Office?

[JanetM]

AndyH, don't forget all the chiropractors out there who tend to the mail carriers...........

I agree with you and will be enjoying the same vent when it comes time to complete the SSAs.

[AndyH]

Thanks for the support Janet. We seem to see many things the same way.