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Posted

Are there any grounds to have a participant's deemed distribution within a 401(k) plan reversed? Are there any reg's that might list certain criteria that must be met? The loans deemed status occurred in 2017, if the record keeper already submitted the 1099-R is there a precedence for reversing it? Lastly, if there are grounds for reversal is it required that the process go through VCP?

Your help is appreciated. 

Posted

IMO grounds would be that it was done incorrectly.  So much stuff is automated and spit out based on what was input to a system, and if the input was wrong, the output might be wrong.  I've managed to prevent a few defaults from happening incorrectly; I imagine it would be harder to fix one that's already happened but that doesn't make it right

Ed Snyder

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