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Posted

Curious how others handle this one!

Hypothetically, say we have a plan that strategically terminated and when paying out the benefits were told to roll them into an IRA.  However, said owners put all of the money into the trust for a new plan they were setting up. How should this rollover be treated/tracked in the new plan?  The new plan does allow rollovers, so no issue there. 

Posted

It’s tracked as a rollover, but that assumes the prior plan actually terminated and the completed benefit election form indicated a lump sum rollover to this new plan. If not, that should be addressed first.

Regardless, sure to offset the 415 limits in the new plan by the adjusted value of the old plan benefit based on the date paid, amount paid, and years of participation (a multiple annuity start date calc is needed for that).

 

Posted

Embedded in the original question is an implication of something else going on.  Perhaps, "owners" trying to hide the "new plan" from other employees?  Failure to identically communicate to all participants?  Other subterfuge?  

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.

Posted

Was this an owners only plan or were only the owners' lump sums rolled into the new plan?

The new plan's document should specify treatment, which should be as a segregate account.

Strategically terminated? But then rollover into a new plan of the same type? Sounds more like some stratgery.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

Posted

you need to lay out the facts better.  if there was a 401k plan termination, they did not have a unilateral right to move the distribution into a new plan.  There would have had to have been a plan merger, not a plan termination.  The only way we can assist is you have to have the facts.  Also, you need to try to be precise in the terms you use of at least provide more information in the way you describe things... e.g., some will say rollover, when it is a transfer, etc. etc. etc.

Just my thoughts so DO NOT take my ramblings as advice.

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