Dan Posted April 10, 2012 Posted April 10, 2012 An HCE has requested a full distribution of his benefit to an IRA. He also deferred wages for 2012. His deferral rate assures he will need a refund of ADP and ACP for 2012. If his entire balance is rolled over now, will the plan sponsor's obligation to refund ADP/ACP failures be satisfied by sending correspondence to the IRA custodian when that time comes in 2013?
ETA Consulting LLC Posted April 10, 2012 Posted April 10, 2012 No, they'll just notify the participant in 2013 that a portion of the distribution was not eligible for rollover because of the failed test. They would merely issue the appropriate 1099R Forms and instruct the participant to remove the appropriate amounts from the IRA. Good Luck! CPC, QPA, QKA, TGPC, ERPA
BG5150 Posted April 10, 2012 Posted April 10, 2012 Is the HCE terminated? QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
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