8955-SSA: Total balance or vested balance?

[ldr]

Good morning to all,

Last year I did a massive review of all of our clients and got the 8955-SSA reporting ship shape, going back as far as we had records and being sure everyone was reported correctly.  (These are all DC plans, mostly 401(k)s).  On page 2, Part III, Item (g), I reported the vested account balances of those who had not yet been paid out.

I am now reviewing a 2018 report for a colleague who has done an 8955-SSA and has reported the participant's total account balance instead of the vested account balance.  The instructions for 2017 and 2018 are not specific, just saying ""For defined contribution plans, enter the value (in whole dollars) of the participant's account."  It really doesn't address the fact that their total account balance and their vested account balance are (often) not the same thing.  

What are the rest of you doing?

Thanks for your advice and tips as always.

 

[Tom Poje]

we always use vested balance, I generate my own report out of Relius because I can save the file in excel and import it into FT William.

Relius also uses vested balance on their report.

lets suppose you have someone who has a balance and is zero % vested and forfeitures occur the year after the year of termination. and for some reason you like to report people on the SSA the year of termination rather than the following year.

now, would you really want to report such a person?

 

[ldr]

Hi Tom,

Thanks, that was my line of thinking too.  Why would you report money that someone would never get?  I will let my co-workers know that we use VAB, not total account balances.  And no, I don't report people on the SSA in the year of termination.  I wait until a year has gone by and if the plan didn't manage to pay them out in that following year, then I report them.  But I do see your point.

[AndrewZ]

Vested balance here also. That's also what FTWilliam exports from its compliance system.

[ldr]

Thank you, Andrew Z.  

 

[Kristina]

The amounts reported on the 8955-SSA are reported to the participant when they apply for social security.  One should never tell a retiree that they have more than their vested benefit available.  This could lead to lawsuits.

[ldr]

Makes sense to me, Kristina.  Seems to be unanimous - VAB it is.