Belgarath Posted September 23, 2021 Posted September 23, 2021 Hypothetical for the moment, but could become real. Participant dies, no named beneficiary. Under the plan default, it goes to the daughter. Daughter is non-responsive, although her location is known. This doesn't really fall under the "can't be located" missing beneficiary. Let's assume after a period of non-response, the plan just cuts her a check. If she doesn't cash it, what then? Does anyone happen to know if Millenium Trust or similar organization will accept a rollover to a beneficiary IRA in these circumstances? (I realize I can contact them - just wondered if anyone already knows). Other options? P.S. - let's assume it is over $5,000, in case it makes any difference in your thoughts.
Peter Gulia Posted September 23, 2021 Posted September 23, 2021 If no one claims the death benefit, there might be nothing the plan’s administrator need decide until the plan provides an involuntary distribution as a § 401(a)(9)-required minimum distribution. If a distribution is no more than the § 401(a)(9) minimum-distribution amount, it’s not an eligible rollover distribution. (If the plan mandates an involuntary distribution of the whole account paid as a single sum, a payer might divide the tax-reporting between minimum-distribution and rollover-eligible portions.) I’ve heard some default-rollover businesses also process non-IRA accounts. Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
RatherBeGolfing Posted September 23, 2021 Posted September 23, 2021 How do we get around the "plan just cut her a check" part? I believe MT and Penchecks both have an uncashed check solution (which is basically an after tax IRA), but in this case you weren't supposed to cut the check in the first place, so I'm not even sure that it is technically an uncashed check. I think the correct way to fix it is to restore the account until you have a proper distribution.
Belgarath Posted September 23, 2021 Author Posted September 23, 2021 I agree. After I thought about it a little more, I realized that just cutting a check, in this circumstance, wouldn't be correct. I just hadn't gotten around to re-posting. Thanks to you both.
baneja Posted September 23, 2021 Posted September 23, 2021 I feel dumb asking this question, but will the PBGC accept the money?
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