SSA for takeover plans

[AlbanyConsultant]

How are we supposed to handle SSA reporting for plans that we takeover? It is rare (at least, in my experience) to get the 5500's going back far enough* to show that all my terminated participants have been previously reported on an SSA, so I'm wary of reporting them with the "D" code when they get paid out because I don't know if that will generate any correspondence from the Social Security Administration or the IRS.

I've sometimes used the approach of reporting all my old terminated participants with a code "B" on the first year's SSA that I do (and preparing to say "whoops, I meant A" for any that I get questioned on), but I don't have any real basis for that.

Is this really an issue that needs to be worried about? Or does someone at the SSA just note that a participant with a "D" this year was never reported before, mutter under their breath about stupid plan administrators, and forgets about it?

* of course, the SSA is not public information (since it contains the SSN)

[david rigby]

This may be an issue of deciding which is worse. IMHO, the worse alterntive is always having to prove a distribution was made when the ex-EE gets the letter from the SSA. So.... I suggest put them on the SSA now, and use the D code as soon as you are able.