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Plan Sponsor/Trustee responsible for losses or forfeiture investments?


John A

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Posted

A Plan Sponsor/Trustee in a daily-valued, trustee-directed profit sharing plan keeps forfeiture money in the funds they were invested in at the time of the forfeiture rather than moving the money to a stable value fund. Forfeitures are reallocated.

1) a) At the time of reallocation, if the funds the forfeiture money is invested in have lost money, is the plan/sponsor trustee required to contribute the amount of the loss to the plan?

b) If so, is this contribution deductible?

2) If the funds the forfeiture money is invested in have earnings, what happens to the earnings (do most documents cover this)?

Posted

Generally, forfeitures are valued as of the date of reallocation. So if funds have a loss, less forfeitures are reallocated, if a gain, more are reallocated. The sponsor is not required to make good on the reallocation.

In practice, some recordkeepers transfer the non-vested portion of the account to a money market fund following distribution of the vested portion, to make it easier to track and value the forfeited amounts that are pending reallocation. This procedure seems to make sense to me.

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Jon C. Chambers

Principal

Schultz Collins Lawson Chambers, Inc.

(415) 291-3004

Jon C. Chambers

Schultz Collins Lawson Chambers, Inc.

Investment Consultants

Posted

I agree with Jon's comments that because forfeitures are valued when reallocated, the plan does not need to make an additional contribution if there is a loss.

To the second question...my understanding is that if there are earnings, you would allocate the portion belonging to the plan year for which forfeitures are being reallocated and just leave the remainder in the "forfeiture" account. I believe that is how we always handled it.

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Carol J. Ringwald

President

CJR Consulting Group, Inc.

Posted

I agree with Jon's comments that because forfeitures are valued when reallocated, the plan does not need to make an additional contribution if there is a loss.

To the second question...my understanding is that if there are earnings, you would allocate the portion belonging to the plan year for which forfeitures are being reallocated and just leave the remainder in the "forfeiture" account. I believe that is how we always handled it.

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Carol J. Ringwald

President

CJR Consulting Group, Inc.

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