"A primary concern for plan sponsors should be any source/fund limits imposed by the plan's recordkeeping system. Since rollovers of non-distributable amount require the preservation of protected benefits and payment restrictions, all contribution sources available for these rollovers will have to be duplicated, at a minimum. To track the five-year recapture period, it may be necessary to create new sources annually.... Plan sponsors should also consider how a proliferation of source/fund combinations could complicate reporting on participant statements."

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