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Posted

A few 401k participants withdrew their accounts on December 28. They subsequently received a dividend in their 401k account < $100 on December 31.

Is there anything to support saying that they are not in the 5500 participant count as of  the subsequent 1/1/XX?  I assume no, but I wanted to see if anyone has run into this situation in that including them in the count will trigger an audit.

Posted

Let me qualify my answer by saying I do not practice in DC administration, but as a practical matter, I would record those residual amounts as distributions payable as of 12/31 and not include those assets or people in the year-end numbers, and make sure that the residual amounts have been paid out or take action now to do so. This was easy to do in the old manual balance forward days, not so sure in these press a button get a filing environments. JMHO

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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