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Posted

Has anyone considered what, if any, type of correction would be corrected for failure to properly map participant's accounts to certain investments when switching service providers? The accounts were supposed to be mapped to the same investments in which they were already invested prior to the transition, but it was discovered that at least participant account was improperly invested and suffered a loss as a result of the improper mapping. The employer/TPA intends to make the participant whole, but I was wondering what, if any, any other corrective action must be taken?

Posted

If I recall the self correction rules you need to also set up procedures to document how the plan will avoid the error in the future.

Flogging might be a good part of the procedure!

  • 4 months later...
Posted

I think you do have the serious answer along with the not serious answers.

You need to make the person whole and document procedures that allow you to avoid such a mistake in the future is pretty much all a self correction requires.

Where you expecting a more complex fix being needed?

Posted

Ideally, the reference to "set up procedures" in Post #3 is double-edged:

- The external vendor should improve their procedures, and should identify those improvements to you (i.e., the plan sponsor), and

- The sponsor should improve its own procedures (let's just call this "proofing").

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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