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Posted

Administrator inadvertently distributed $150 out of participant's Roth 401(k) account. I am wondering whether the distribution should be reported on 1099-R and subject to premature distribution penalty (participant not eligible for qualified distribution)? I can't seem to find any exemption from the premature distribution penalty for this type of mistake. If the participant agrees to put the money back into plan, is it just a wash and there is no 1099-R reporting and no penalty?

Posted

Was money available in another source and did the participant otherwise qualify for an available distribution option? Which would make it a simple administrative/recordkeeping error that might be fixed in the back office?

Kurt Vonnegut: 'To be is to do'-Socrates 'To do is to be'-Jean-Paul Sartre 'Do be do be do'-Frank Sinatra

Posted

Have the person pay it back. W/ interest. No harm, no foul.

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

Posted
Have the person pay it back. W/ interest. No harm, no foul.

And have a procedure in place to help ensure it doesn't happen again.

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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