jkharvey Posted September 5, 2014 Posted September 5, 2014 I'm not sure if this belongs in this forum or over in distributions. 401k plan has assets invested at large platform. Participant has been receiving RMDs for a few years and dies during 2013 before the rmd was distributed for that year. The beneficiary is a trust for the participant's children. Rather than make a distribution of only the RMD amount, the platform moved the entire account balance into an account ini the plan and named it "revocable trust for XYZ participant". the RMD was then distributed from that account. Is it permissible for a nonperson like this to be a participant in the plan?
My 2 cents Posted September 5, 2014 Posted September 5, 2014 How is this different from a situation where the participant dies and the beneficiary is the participant's estate (either by default or by virtue of the participant having explicitly designated his or her estate as beneficiary)? In that case, after the death of the participant and before the money is paid out (may take some time if the beneficiary is the estate!), wouldn't the plan be holding money belonging to a non-natural person (trusts and estates are persons, but not natural persons)? I am sure that there are more than a couple plans out there with accounts whose beneficiary is either the participant's alma mater or a church or other non-profit institution. There cannot be an issue with the plan holding assets owed to such an institution pending completion of arrangements to make the payment, could there? Always check with your actuary first!
jkharvey Posted September 5, 2014 Author Posted September 5, 2014 Thank you. I had not looked at it in that perspective.
Bird Posted September 5, 2014 Posted September 5, 2014 And FWIW, they do it that way for 1099 purposes; the 1099 SS # feeds off of the database. It's still an account for the deceased participant. Ed Snyder
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