reimburse plan expense erroneously charged

[Scuba 401]

our office set up an account improperly and its been charged a flat annual custodial fee. we want to reimburse the client for the overcharges. can we do so and can they put the money into the plan? alternatively can we just put the money back in the plan?

[QDROphile]

Who gets the refund depends on who paid the charge.

[Scuba 401]

expense was deducted from the plan assets. we want to give the money back to the plan if possible.

[BG5150]

If it was a mistake, I would say that it must be repaid to the plan account(s). With earnings, no less.

As long as the custodian is disgorging the improperly paid fees. So this would be a correction rather than a reimbursement.