Schedule SSA for terminated plan

[wsp]

An old client brought in a Social Security Administration letter sent to a participant letting them know about an account balance that they may be due from the plan. SS letter was generated from the 1999 SSA filing. Unfortunately, the SSA filing was incorrect. For some reason the recordkeeper at the time reinstated forfeitures, made all participants 100% vested, and showed about a dozen people on the SSA as being owed account balances. Life goes on and participants show 100% vested account balances but nothing was done on them. 3 years later the plan terminates. During termination process this was caught and account balances were forfeited and allocated. However, those participants were not reported on the 2002 final filing. Hence the letter generation.

Certainly I can create a form letter for each participant showing them that do not have a vested account balance, but it would be much easier to stop that letter from generating. Should I file an amended 2002 return with a new schedule SSA at this point? Or is it simply too late?

Fortunately none of the above actions were mine as I started in June of 02 and final filing had already been completed. But, still my job to clean up the mess....

[Bird]

I think it's too late.