"Participant A requires a 415 refund every year, and the participant and/or plan sponsor don't change anything, so it keeps happening, so we do a distribution each Fall. For 2022, we processed a refund in November 2023, but in January 2024 A called to say that the refund didn't reach her. After some panic, it was re-processed in January 2024. The refund for 2023 was processed November 2024, no problem. Now upon further discussion, A realizes that she did get the distribution in November 2023, so she got it twice. A is 49 years old, not eligible for any in-service withdrawal from the plan. So step one will be to try to get A to return one of the distributions ($11K). But she's already got a 1099R for it, and getting a recordkeeper to change it is going to be nigh-impossible. So, really, what is A's incentive to return the money? She's paid the taxes on it; if she returns the money, it gets taxed again on the way out? I suppose we could try to set up an after-tax source at the rk, but.... still, why would A want to return the money? For the plan sponsor, they have to ask for the money back. And if A doesn't return it....? Document the process, multiple requests, but ultimately they can't really DO anything if she doesn't return the money, as far as I can tell. What am I overlooking?"

"Participant designated family member before marriage, gets married, and then gets divorced. Is the initial beneficiary designation reinstated or did the marriage void it?"

"The client moved to being a co-op, meaning all employers have an equal ownership of the company. 17 current employees, so each employee technically owns more than 5% of the company. Am I wrong in thinking that this means everyone is an HCE, and therefore no ADP Testing is required? Obviously, if they add people and have more than 20 employees that would have to be re-evaluated. But currently, no testing would be required correct?"

"SECURE 2.0 has changed some of the information required in the 2024 Annual Funding Notices due during 2025. Does anyone know if we are still expecting a model notice to be released or are firms just individually changing the current model annual funding notice to comply with the new requirements?"