402(g)Limits Small Distributions

[Guest Frank Jackson]

This year I have encountered a number of 402(g) violations under $40.00. Is there any de minimis rule for small distribution amounts? This is especially troublesome for amounts under $10.00. Sometimes there are amounts under $1.00. Has anybody established a threshold for their clients? If so, should these small amounts be removed from the participant accounts? Could they be applied to expenses or used to reduce future contributions? Another twist, if a check charge is accessed for this transaction (say $40.00) could that be used as the threshold and then the money could be absorbed as an expense.