KaJay Posted July 24 Posted July 24 A 403(b) plan received two rollover checks from a 401(k) on behalf of a participant age 74. Check #1: Pre-tax deferrals ($4,915) Check #2: Non-Qualified Roth basis ($10,447) with earnings ($590) [First Roth contribution = 2024] The 403(b) was informed that the participant's 2025 RMD for the 401(k) was not distributed to him prior to the rollover. The participant is not eligible to make regular contributions to the 403(b). The 403(b) has not cashed the checks yet because it does not want to deposit ineligible amounts. It is wondering if it can return the checks to the 401(k). What is the cleanest way to correct this?
CuseFan Posted July 24 Posted July 24 Return and re-issue proper checks is probably the best way to fix. R Griffith, acm_acm, KaJay and 1 other 4 Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
KaJay Posted July 25 Author Posted July 25 @CuseFan Thanks for your quick reply. The plan decided to do just that. The checks will be returned to the sending firm.
rocknrolls2 Posted July 25 Posted July 25 I agree with CuseFan that the checks should be returned. Inform the participant that s/he needs to have the RMD paid out before there are any eligible rollover distributions that are permitted. Once the RMD has been satisfied, then s/he can make the rollover. Two other questions: why are Roth 401(k) amounts being rolled over? and (2) question for the 403(b) plan: if the participant cannot contribute to the 403(b), why is it willing to accept a rollover from himher?
david rigby Posted July 26 Posted July 26 Another point: Statement in the original post that the 403b plan "was informed that the ... RMD ... was not distributed". Who did the informing? If someone knew it was not distributed, why didn't it get done? This may seem trivial, but it goes to the very serious question of both competency and thoroughness of someone in the administrative chain, perhaps multiple someone's. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
KaJay Posted November 7 Author Posted November 7 @david rigby I agree with your last statement! The 403(b) rollover request paperwork of the receiving firm explicitly states RMDs are not eligible for rollover and the participant acknowledges he/she must inform the sending firm it cannot include the RMD. While this appears to be a good faith effort of the receiving plan, likely to avoid a correction like this, one would imagine the 401k provider should "know better".
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