"Record Keeping platforms - these are most of our distributions by far. TPAs generally get notification, log in, check vesting and approve. Is anyone doing anything extra to be protected? I'm thinking of requiring the plan sponsor to contact the participant (who likely is terminated) to confirm their request if the distribution is over say $10,000. A 3rd party could have hijacked their login credentials. If a
problem, I'd expect the plan sponsor would point fingers at the TPA - 'you approved it.' I'm not sure all platforms require both TPA and plan sponsor. We do our part but we don't know if the sponsor always has to approve as well. We will need to confirm.
"Broker accounts and DB plans - for these, we provide distribution packets, plan sponsor requests funds be sent to us, we issue checks,
deposit tax into EFTPS as needed and do tax reporting. We do not get funds for larger amounts - brokers get letter signed by Trustee to distribute as the participant has elected. For all check distributions we request driver's license unless small (under $1,000) to be provided to us at the same time they send their election form - not separately. Still there is risk the election form could have been completed by a 3rd party who also had
access to the driver's license.
"All ideas welcome!"
