Controlled Group Transfers

[Andre3000]

Companies B and C are subs of mothership A. The mothership has told Company B that one of its subs (call it D) has been transferred to Company C.

Effective 1/1/15 D is no longer contributing to plan B and deferrals are going to plan C. The natives in sub D want their assets in the plan with Company C and out of the plan with Company B.

• Is C required to take all assets or just actives of those in D?
• Can ppts in D elect to keep their money in B if they so choose (I'm told B has a brokerage window and C does not)?

It seems on paper that this should be pretty straightforward but C's RK is talking blackout on both sides. B's RK doesn't know this is happening yet either.

[Kevin C]

Mothership A appears to be in charge, so it would decide what, if anything, happens. Depending on what they want to do and the plan document provisions, there may be more than one way to get the same result.

A blackout enters the picture if the transfer keeps participants from being able to take certain actions for more than 3 business days, With at least two different recordkeepers involved, I would plan on there being a blackout.