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Posted

Assume a participant severs from employment with a nonforfeitable account less than $7,000 (and more than $1,000) and the plan provides an involuntary distribution.

Despite that small size, the account includes both Roth and non-Roth subaccounts. (For example, elective deferrals were Roth and matching contributions were non-Roth.)

Assume the participant, after the proper notices, does not specify her preference for the distribution, invoking the plan’s default rollover.

Does a plan's administrator with its service provider pay separately the Roth and non-Roth amounts?

Or does a plan’s administrator and its service provider pay one sum, and instruct the default IRA provide on the distinct Roth and non-Roth amounts?

Does a default IRA provider separately account for the Roth and non-Roth amounts?

Does a default IRA provider put this in two IRAs? Or in one IRA with subaccounts?

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted

For the particular matter I’m now working on, I found my answer:

An Ascensus recordkeeper agreement with an add-on for using Ascensus as the default-IRA provider says two IRAs—Roth and traditional.

But is that way universal?

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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