"Client is terminating a 401k Plan. There is a sizable amount in the forfeiture account. Even after paying expenses, there will be a balance left over. The document says that forfeitures are allocated first to restore previously forfeited amounts to participant accounts. Thereafter, remaining forfeitures are used to:

• offset Plan expenses
• reduce future matching contributions
• reduce future nonelective contributions

Since we are terminating, and thus there will not be any future contributions, how should we allocate the remaining forfeiture balance? Pro-rata to participants according to??"

"With the new 2023 forms, this number will be required. The IRS has informally indicated that this will be available as part of the 5500 data sets. So, anyone can look up the opinion letter serial number for a given TPA, and essentially obtain your client list for 5500 filings under each pre-approved plan you sponsor. Is the ARA raising any hell on this? Seems pretty serious to me!"

"We are TPA on a plan that requires the independent audit report for the 5500 due to size. The plan is with a large recognized national 401k vendor. The auditors are currently doing a review of selected participant distributions. They were unable to match the amounts forfeited on two individuals based on the vesting so of course came to me for explanation. I also could not match the amounts that were paid out/forfeited so I checked both my system and the participant hard copy distribution form. Both of those reflect the proper vested percentage for each participant. I then went to the vendor for explanation as to how the vested percentage was computed. In both cases the participants had taken a Coronavirus withdrawal back in 2020 and the vendor is telling me that affected the final payment and subsequently the forfeitures for each participant. That would indicate to me that a portion of the Coronavirus distribution was made from non-vested funds. We're not talking about a lot of money here because this particular client limited the CVD to $3,450 per participant. Both participants had deferral accounts and for one of them the vendor didn't even take 100% of the deferral account before taking from the Employer sources.... I was unaware that it was even allowed at the time to take non-vested funds as part of the CVD distributions. Does anyone know if this was a thing?"

"I understand that not all plans allow for in-service distributions. And I understand that you must die, become disabled, be terminated or reach retirement age. But all that aside, can a participant request and can a plan make an in-service distribution to an active participant that isn't considered a hardship in-service distribution? Of course the payout would be taxed and coded early. Is this possible?"