1099 on 403b forfeiture

[Guest PeteJ]

I've encountered an odd issue which is not in my scope of knowledge.

From what I understand, forfeited balances in retirement plans can only be used by the Company for a hand full of things such as promoting the plan, brouchures for the plan and/or paying the benefit plan auditor.

If the benefit plan auditor is paid from forfeited balances in the retirement plan but the check is cut on the plan administrators check stock, who is responsible for the 1099?

Although, it is third party check stock, I'm leaning towards us, since we had control over the funds and directed the plan administrator to do so.

Please advise.