It seems that separate Form W-2 reporting of regular, after-tax 401(k) contributions (i.e., non-Roth contributions) is more of an optional than a mandatory item that may be reported in Box 14 of Form W-2 -- correct? The employer will include the after-tax amounts as part of wages subject to tax and withholding getting reported. The question is, do they also need to separately break out and report the after-tax 401(k) amounts elsewhere on the W-2? They prefer not to do so, which I suppose is understandable from an administrative perspective but I can see some benefit to including this information for transparency and confirmatory purposes. (That also could prove useful if questions arise as to a participant's basis in the after-tax account under the plan -- e.g., if the record keeper loses track of that information going forward.)

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Does anyone have a suggestion for fixing an ADP refund for 2017 that was done (by a prior TPA) in May and then done again in October? Two people were paid out twice.

I have a terminating DB Plan covered by the PBGC that recently paid the liability to the PBGC through the missing participants program. I had confirmation from the PBGC that the plan was eligible to use the missing participants program. The participant has just reached out to the administrator, and claims that the paperwork just came in the mail (doubtful -- the paperwork was sent a few months ago, and again as a follow-up). The participant wants to roll over his lump sum into an IRA. Can the plan sponsor ask the PBGC for the money back, in order to be able to pay the participant? Or does the participant need to wait until all of the paperwork is finalized and then seek payment from the PBGC?

A participant in one of our client's 401(k) plans has died. The beneficiary form lists her trust as the beneficiary. The decedent's daughter is the sole beneficiary of the trust. The trust's administrator is asking if it is possible for the plan to pay the daughter directly to an inherited IRA, rather than pay to the trust. The plan document does not have any language pertaining to this particular request. Has anyone run into a similar request? Our thinking, as the TPA, is to have the Plan Administrator refer to their legal counsel.