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Posted

I am working on a plan that failed the ADP test for 2014. 2 HCEs need refunds. They terminated in October and took their assets out in December 2014. Both rolled their assets over to IRAs.

So what do we do to "correct" the test failure? let these former participants know that they need to take $x out of their IRA as an ADP refund?

QKA, QPA, ERPA

 

Posted

See instructions to form 1099-R it is explained in detail.

You can also search this site, I think there are few threads that covered this, possibly even one started by me.

Essentially you need to notify them to pull the money out of the IRA and send them amended 1099-Rs since a portion was not eligible for refund.

Posted

if they need new 1099-rs, then I assume John Hancock needs to get involved, as they held the assets....

Probably. They are most likely going to want something from the TPA and/or client authorizing them to do it. I know we've done it with a few packaged vendors and they all have slightly different procedures. Some are easier to work with than others.

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