Excess DB Assets, seven years of transfers is up, but still funds remaining. Now what?

[BG5150]

Sponsor had excess DB assets and moved to a QRP in a suspense account.  We have been transferring roughly $50k a year (whatever the 415 max is per year).  2019 was the 7th year.

There is still about $180,000 left in the account.  What happens to those funds?

[Mike Preston]

4 hours ago, BG5150 said:

Sponsor had excess DB assets and moved to a QRP in a suspense account.  We have been transferring roughly $50k a year (whatever the 415 max is per year).  2019 was the 7th year.

There is still about $180,000 left in the account.  What happens to those funds?

No guidance. I've been giving clients advice to contact an Erisa lawyer with the expectation that they will be told to continue with maximum allocations until plan is terminated. 20% excise tax applies to amount reverted.

[chc93]

6 hours ago, Mike Preston said:

No guidance. I've been giving clients advice to contact an Erisa lawyer with the expectation that they will be told to continue with maximum allocations until plan is terminated. 20% excise tax applies to amount reverted.

And hopefully, all excess will be allocated before the plan is terminated, and therefore no reversion, and consequently no excise tax.  Is this correct?

[Mike Preston]

Seems right to me.