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Posted

Some participants in a plan took final distributions who, as a result of termination of employment, defaulted their loans.

However, the office preparing the 1099-R's did not issue them for the loans, only the distributions. Evidently, this has gone on for some years.

How can we correct this? Can we issue 1099's currently?

Are the ones that happened the past couple years eligible for SCP and older ones VCP?

These aren't loan problems, but reporting problems as we see it.

As always, your thoughts are appreciated.

QKA, QPA, CPC, ERPA

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

Posted

For 2012 - I'd issue corrected 1099-Rs now.

For 2011 and earlier it is a stickier issue. I'm not sure which VCP program this would fall under but it would seem that VCP should be able to handle something like this.

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