Participant not deleted from SSA after payout

[Bill Presson]

We have a plan that we've been TPA for about 10 years. Sometime in the distant past a participant (Y) terminated employment with a vested benefit and was reported as such on the SSA. Following that, we assume, she was paid out since there was no record of her on the information we received. It also appears that no additional notation was completed on another SSA indicating that she was paid out.

We don't have a 1099 to show her. Any thoughts or suggestions on other avenues available to confirm the distribution? We're pretty sure it happened between 1997-1999.

Thanks.

[david rigby]

Following that, we assume, she was paid out since there was no record of her on the information we received.

Was the participant a VT before you took over as TPA?

- If no, then you would have found (or not found) a distribution in the assets, thus confirming the current status.

- If yes, then this sounds like a data question for the plan sponsor to answer.

Just a guess.

[Bill Presson]

Following that, we assume, she was paid out since there was no record of her on the information we received.

Was the participant a VT before you took over as TPA?

- If no, then you would have found (or not found) a distribution in the assets, thus confirming the current status.

- If yes, then this sounds like a data question for the plan sponsor to answer.

Just a guess.

Yes, she was paid out before we took over. The sponsor is confident of the distribution as well, just no 1099 copy.

[masteff]

My answer to the participant would be along the lines of...

"As part of it duties, the SSA helps people keep track of retirement accounts at former employers. It does this by requiring employers to report such accounts in the year after someone leaves employment. In the past, confusion was created because the SSA didn't require follow-up reporting when people closed out their accounts. About six years ago, newer rules were added to require such follow-up reporting of closed account. However, you received your distribution prior to that rule being in place. This means the SSA was never told when your account was closed. We have done an exhaustive search of our records and confirmed that you do not have any benefits remaining in the plan. We apologize for the confusion that the SSA notice may have caused."

(I worked at a company w/ 4500 actives and 1500+ retirees... I've long since had that speech well rehersed).

Is the former participant demanding to see the 1099 or are you simply trying to find as it would be the most conclusive evidence? Either way, a 1099 from the late '90's is generally well past its records retention requirement.

[Bill Presson]

My answer to the participant would be along the lines of...

"As part of it duties, the SSA helps people keep track of retirement accounts at former employers. It does this by requiring employers to report such accounts in the year after someone leaves employment. In the past, confusion was created because the SSA didn't require follow-up reporting when people closed out their accounts. About six years ago, newer rules were added to require such follow-up reporting of closed account. However, you received your distribution prior to that rule being in place. This means the SSA was never told when your account was closed. We have done an exhaustive search of our records and confirmed that you do not have any benefits remaining in the plan. We apologize for the confusion that the SSA notice may have caused."

(I worked at a company w/ 4500 actives and 1500+ retirees... I've long since had that speech well rehersed).

Is the former participant demanding to see the 1099 or are you simply trying to find as it would be the most conclusive evidence? Either way, a 1099 from the late '90's is generally well past its records retention requirement.

This basically what we had planned. And the participant is not yet asking for proof. Just trying to get my ducks in a row before responding.

Thanks much.