1099 for QDRO

[thepensionmaven]

Participant and spouse split her account balance in 2016 according to the terms of a QDRO

Plan account is pooled account, upon instructions from the client, since the spouse was rolling over, the brokerage firm wrote the check directly to the financial institution.

I assume the spouse should be issued a 1099, code G with the plan as the payor and the participant's account would show the money coming out of her account.

However, the spouse is not a participant.

Is this cause for concern?

[RatherBeGolfing]

Is your concern issuing a 1099 for a non participant?

That isn't a problem, you are simply reporting who had income from the plan and how much was taxable. 

[ESOP Guy]

I don't see a problem. 

Maybe one could make a case in terms of recordkeeping the plan should show the assets were split and the Alt Payee got her own account.  At which time she did become a participant for many purposes (for example it has always been my the Alt Payee who keeps their balance in the plan is due all notices a participant is due).  Then there was a benefit payment from her account.

The 1099-R code is correct with a G.

I don't see a problem with the rollover being done as it was. 

[CMarkB]

Consistent with what ESOP Guy wrote, see the below.   

"A spouse or former spouse who receives QDRO benefits from a retirement plan reports the payments received as if he or she were a plan participant."   https://www.irs.gov/retirement-plans/plan-participant-employee/retirement-topics-qdro-qualified-domestic-relations-order