Plan Terminated - Residual Dividends in Following Year - 5500 Required?

[401(k)athryn]

A plan terminates in 2018 and all assets are paid by 9/30/2018.  In March 2019, residual dividends hit a few accounts and are paid out to the participants.  I was planning to file a final Form 5500-SF for 2018 with an ending balance of $0 (accurate).  Do I need to file the final for 2019, instead?  In this case, both the beginning and ending balances will be $0 with a small amount of earnings and distributions.

If you think I would need to file the final for 2019, then I assume I would have needed to amend the file Form 5500-SF for 2018 if I had already filed it. 

I am frustrated with the investment platform because I can't imagine why dividends posted so late, although I would guess this issue is common when plans pay out final assets in December.  I did not quote the plan sponsor a fee for a 2019 filing because 2018 was intended to be the final.  I realize it is not a ton of work, but still.

 

 

[Peter Gulia]

For 2017 and earlier years, were the plan's annual reports on the cash-receipts-and-disbursements method of accounting or an accrual method of accounting?

 

[Bird]

I've sometimes taken the position that such trailing dividends as well as the resulting payouts were "pending" - I guess you could call them accrued.  I'm not saying it's right and ya takes yer chances I guess but...how is it going to come up in the first place, and in the second place, I think I could talk my way through it if necessary.

Sux that this would happen after the plan was term'd in September...

[401(k)athryn]

Thanks, Bird.  I believe you are indicating that you might show these dividends and distributions that occurred in 2019 as accrued activity for 2018 and report these amounts on the 2018 FINAL Form 5500.  I had not thought of that, but it actually makes a lot of sense.  

[Florence]

I am going through the same situation currently.  We have a terminated Plan and we did the final 5500 in June 2018, final payout 5/25/2018.  1099Rs were issued to all participants end of 2018 for their distributions.  In February 2019, additional dividends were posted to several participants' accounts.  Subsequently rolled into their IRAs.  I have been contemplating the impact on the final 5500, as well as whether 1099Rs need to be issued for 2019 for these (very small) residual amounts.

ANY THOUGHTS...

[chc93]

One thought is that the trailing dividends were from investments that were already rolled out of the plan and subsequently became the property of the rollover account.  So these dividends should be property of the rollover account, and no additional work for the plan is necessary... (2 cents worth?)