Terminating a retirement plan is complicated. The importanceof having a well thought out plan in place before beginning theplan termination process is imperative becausemaking mistakes can be costly.

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To better understand why plan sponsors were making mistakes in qualifiedplan terminations, the IRS Employee Plans Compliance Unit conducteda “Termination Project” in 2011. Over 75% of the sampled sponsorsmade errors!

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So what kind of errors did plan sponsors make?

  • Did not file a final Form 5500 series return

  • Did not actually terminate their plan

  • Mistakenly indicated the plan was terminated when it wasfrozen

  • Mistakenly used the same plan number from a previous ordifferent plan

  • Distributed all plan assets but didn’t mark the final Form 5500series to show it was the final return

  • Distributed all plan assets but did not indicate zero assets atthe end of the plan year

  • Did not distribute all plan assets as soon as administratively feasible (*generally within12 months)

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Why did plan sponsors make these errors?

  • Length of time required to find missing participants

  • Difficulty in distributing certain types of plan assets (realestate or partnership investments)

  • Not aware all plan assets must be distributed

  • Not aware of the difference between a frozen and terminatedplan

  • Not aware there were still assets in the trust

For more information on the “Termination Project” conducted bythe IRS Employee Plans Compliance Unit click on the link –(IRS Termination Report).

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This is the second video of a three-part series on DC planterminations, presented by Mike Wilder, Vice President of ClientServices, Retirement Clearinghouse.

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