An inadvertent Screw-up

[richard]

Companies A and B are NOT in the same controlled group (or affiliated service group, etc.) However, there is overlap among these two companies, for historical reasons.

Company A and B each sponsor calendar year pension plans. Management of Company A "administers" both plans. (Don't worry, the named Plan Administrator is the plan sponsor of each plan.)

An employee of B terminated employment and was paid a lump sum -- out of Plan A's assets. Oops! The lump sum represented about 0.01% of Plan A's assets and 1.5% of Plan B's assets. Quite minor.

Now, how to correct? APRSC? VCR? Other? Any time restrictions? (It happened around October 1998; we just discovered it.)

(There is no history of errors or abuses, both plans are properly administered; just "an inadvertent screw-up").

[Guest Ray Williams]

This sounds like it should qualify for APRSC. First, get out your APRSC checklist and see if there is a catagory where this fits. Assuming that it does, document the correction and the Plan Administraors' approval of the correction