"If a plan distributed assets to a participant who wasn't 100% vested, in a situation that wasn't a distributable event, is anyone on the hook for paying back the plan? The way I'm reading EPCRS, it seems that if the employee was still employed when it happened, no corrective contribution would need to be made to the plan. What if, 6 months later, this employee terminated? Would that trigger a repayment of the forfeited amounts if the employee never paid the plan back?"

"A one-participant DB plan terminated in December 2020. Participant received full distribution on 12/22/20, amount in excess of $2 million. I've read the instructions for Form 945 and Publication 15. Publication 15 refers to filing for Form 941. If we use that, and the lookback period was zero, is the client a semiweekly filer? Or does the next day filer rule apply?"