Takeover plan only has a few past SSA's

FreeERISA cannot provide SSA's anymore.  If the employer doesn't have them, is there any other source for this information?

Why do you care?  

We like to get the SSA's that were  filed for 2 reasons.

The first is to make sure the proper participants were reported.

The second is to remove participants who were reported and have been paid their benefit.  This prevents participants from getting the letter from the SSA saying they "may" have a benefit due.

Mjke

Yep, every actuary with a takeover relationship has had the same thoughts.  Generally, we just remove (code D) as many (lump sums) as possible next filing.  If the person has previously been reported as D, so what?  (To be precise, we assume such reporting is "no harm, no foul".)

I agree with David.  No issues in deleting someone who was never reported, and if they weren't reported in the past, that isn't your problem - or just report them again if you feel the need.

I never knew you could get SSA from FreeERISA.  I would have thought privacy concerns would have stopped that.

To answer your question I know of no source besides the plan sponsor or the old TPA (if any). 

I also find we have no issues if we keep with my philosophy of, "when in doubt D" on an SSA. 

You can always report anyone who should have been reported in prior years as a B code.  I'm assuming you have the information necessary to calculate their benefits.  If they have never been reported as an A, that is not your issue.  (I've not heard of this being an issue unless the plan comes under an IRS audit.)

Then be sure to report all D codes and you are done with that participant.

I remembered thinking about this years ago... reporting a participant as a "D" without ever having that participant reported as an "A" would raise a flag and possible penalties for not reporting an "A" when required  But I guess with manpower shortage, this kind of audit will probably never be done.

I have not heard of any D reporting raising the audit flag.  And even if it did, it is more important to stop any benefit notification letters and the time suck to respond to participants who were paid out years ago.

1 hour ago, Kristina said:

I have not heard of any D reporting raising the audit flag.  And even if it did, it is more important to stop any benefit notification letters and the time suck to respond to participants who were paid out years ago.

I agree with you.  When in doubt, we have reported D's. 

But we had at least one big client that knows he reported the D participants, but some of these participants got that SSA letter anyway.  He insisted that the SSA reporting wasn't working, and therefore not necessary.

22 hours ago, chc93 said:

But we had at least one big client that knows he reported the D participants, but some of these participants got that SSA letter anyway.  

I have always wondered if that wasn't part of the problem!

It would be interesting to know if those D's that didn't work are from back when all SSA's were entered manually by the government.  It really hasn't been all that many years it seems like that there was a good way to electronically submit these forms. 

I know I had some large clients that there SSA was many pages of paper someone had to enter.  Easy to see a typo to someone just not bothering with all those D's.