"Participant died in 2023. He did not receive his 2023 RMD. Who would receive the RMD.? Who pays the tax and receives the 1099?"

"We have an employer with 100% of employees in its 403b plan that is considering terminating the 403b plan in order to accomplish two things: [1] Start up with a new 403b; [2] Provide access to cash for one of the employees. My understanding is that a termination results in a distributable event for employees, where they can either get the cash or rollover to another institution. If a rollover to another 403b is possible, don't the regulations state that the employer cannot participate in another 403b for 12 months starting the date the funds are liquidated due to termination? Meaning the funds that make it to the new 403b institution will need to just 'sit there' for a year and employees will lose out on contributions that would have otherwise been sent to the initial 403(b). Is my understanding correct?"

"Where or what details can be provided by ERISA guidance that say allocations must be deposited into the investment election that the participant chose or was defaulted too? I know this is a Plan Failure but does it disqualify the Plan? example -- company provides small catch up profit sharing contribution. It was requested for these funds to be deposited into specific accounts that do not follow the QIDA."

"Just saw a brief article from Fred Reish on this. I'm wondering why an employer would want to get involved in this, if approached by a recordkeeper, etc.? Seems like yet another possible fiduciary issue, yet another possible complication or item that may bring up questions, etc. From my viewpoint, a participant has been notified about the cashout. They haven't responded, so account is rolled to IRA. Period. No further involvement -- wash your hands of the whole thing. The participant then can do anything they want with the IRA. Don't know what other thoughts folks might have?"

"Anyone have a sample notice they have seen / prepared that they are willing to share? I assume some of the big providers have put something together...."