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I have a long time client that has both a 401(k) Plan and a Cash Balance Plan. These plans have been in place for quite a while and each has 1 -2 million in assets. Here's the problem, the defined benefit plan's assets consisted of all CD's. As they all became due during 2025, the proceeds from the CD's were mistakenly transferred to the 401(k) plan leaving the DB plan with zero assets. 

I don't see any good solution for this problem. If I was pressed, I would suggest transferring the assets back into the DB plan with an estimated income adjustment. Using this approach, how much risk would there be if the plan would be audited in the future? Could the risk potentially be as great as a disqualification of both plans?

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