Distribution Timing

[Dazednconfused]

Plan is pooled and has yearly valuations on 9/30/10. Distribution timing states 'as soon as administratively feasible following the time specified below', which then has 'immediately following severance' checked.

If a participant term'd on 11/1/10, submitted paperwork, I think that the distribution should be processed (based on prior 9/30/10 val) and if any other, EE, ER contributions come in for the current plan year pay them a second distribution (if needed) upon completion of the next valuation on 9/30/11. Normally I think this type of plan set up should have 'next valuation' for distribution timing but not the case here.

Even though it is a yearly valuation, I don't think it would be 'administratively feasible' to make a participant wait until the next valuation, almost a year with the immediately following severance option selected.

Just wondering how others approach this one.

Thanks all!

[Bird]

You're right, this isn't the ideal scenario for this type of plan. I think you can do what you propose; I would definitely be uncomfortable arguing that "as soon as administratively feasible" could mean waiting until after the end of the plan year. But I would include any employee contributions that were made in the interim, and any employer contributions that are definite - a fixed match with no EOY provision, e.g. I guess arguably the Account Balance to be paid doesn't include those items since they are technically allocated as of the next val date, but who is going to argue that point?