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Posted

I have a few force outs to accomplish. Does the initial notice need to be sent by certified mail?

Also, regarding lost participants, if we run their name through an internet search, is that enough due diligence?

Finally, I have a lost participant with an account of approximately $6,000. We had done a few searches with no luck. What is done in this case? He has been lost for 12 years.

Posted

1 - yes

2 - see Field Assistance Bulletin 2014-01 (you can follow link below)

3 - unless the plan is terminating which will allow cash out above the $5K you can not cash them out without their consent until the later of age 62 or the Plan's Normal Retirement Age.

https://www.irs.gov/Retirement-Plans/Missing-Participants-or-Beneficiaries

http://www.dol.gov/ebsa/regs/fab2014-1.html

For #3, check the plan document. The cashout threshold may be as low as $1,000. Many plans lowered it to $1,000 after the auto-rollvoer rules came out. They didn't want to deal with the hassle of setting up IRA's. Now with the proliferation of companies that welcome these small rollovers, and the ease with which an agreement can be set up, it's reasonable again to have a $5,000 cashout level again. But not everybody changed back.

And this bears mentioning, as I've seen it come up recently: Check the plan doc to see if unrelated rollvoer money counts or doesn't count toward the threshold.

QKA, QPA, CPC, ERPA

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

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