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Excluding Pre 1/1/09 Contracts

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Individual participant contracts are excluded to avoid the audit requirement. But now they are going over regardless. The client of course no longer wants to go to the trouble and expense of segregating out the pre-1/1/09 contracts and the auditor would prefer not exclude them because all of the trust reporting includes them.

How are people handling this? Two options come to mind, Transfers Into Plan and Rollovers (I guess it is called "Other additions, including rollovers").

Austin Powers, CPA, QPA, ERPA

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