PS Posted October 12, 2021 Posted October 12, 2021 Hi, One of the terminating plan there are few participants with balance in the MPP source, this was from the pervious plan. The plan has elected for optional, so if a participants does not take action can the plan sponsor direct to have the funds rolled over to an IRA account for the ones who have balance in the MPP source? or should it be an Annuity? Thanks
CuseFan Posted October 13, 2021 Posted October 13, 2021 MPP source is subject to QJSA rules, so w/o participant waiver/consent and spousal consent, if applicable, you must purchase an annuity. That's why clear communication, forms and follow up are so important. If you tell someone, hey, if you don't return your properly completed forms, then instead of getting that $20,000 portion of your account you'll get $25/month 10 years from now when you're 65, they'll likely respond. Luke Bailey 1 Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
PS Posted October 13, 2021 Author Posted October 13, 2021 Yes, the communication and forms will be sent. but if they don't respond can it be rolled over to an IRA account?
Bill Presson Posted October 13, 2021 Posted October 13, 2021 43 minutes ago, PS said: Yes, the communication and forms will be sent. but if they don't respond can it be rolled over to an IRA account? No. If they don't respond they get the annuity. Luke Bailey 1 William C. Presson, ERPA, QPA, QKA bill.presson@gmail.com C 205.994.4070
PS Posted October 14, 2021 Author Posted October 14, 2021 That's what I thought, thanks for confirming.
PS Posted October 14, 2021 Author Posted October 14, 2021 Is there any document that I can refer since my client is looking for some kind of reference material on this.
Belgarath Posted October 14, 2021 Posted October 14, 2021 I assume your plan document is an IRS pre-approved document? If so, it should already have this language. Admittedly, sometimes rather convoluted to wade through it....
BG5150 Posted October 14, 2021 Posted October 14, 2021 I think the PBGC will take the funds... QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
CuseFan Posted October 14, 2021 Posted October 14, 2021 2 hours ago, BG5150 said: I think the PBGC will take the funds Great point! I know that on a DB termination PBGC considers an unresponsive participant as missing, I don't know if consideration extends to DC plans or the participant must be truly missing. Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
BG5150 Posted October 14, 2021 Posted October 14, 2021 They do: https://www.pbgc.gov/prac/missing-participants-program QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
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