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CPA Corner  

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Avoiding Retirement Plan Operational Errors

n most cases errors in the administration of a retirement plan result from the ERISA administrator’s lack of understanding of the provisions in the plan document. A clear example would be the definition of compensation. Does it exclude some part of compensation, e.g. bonuses, is it based on the plan year or calendar year? Understanding eligibility requirements as they relate to entry dates in another potential for an operational error when an employee enters the plan too early or too late. To avoid errors of this type, the plan should have a written administrative policy that identifies who is responsible for the various functions required to manage the plan. Will the plan sponsor or the payroll vendor be responsible for monitoring timely deposits of employee deferrals? Does the plan document indicate when and how often an employee can make changes to their deferral election?

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Is Participant Data a Plan Asset?

Is Participant Data a Plan Asset? This question is now the basis for a new claim against record-keepers servicing 401(k) ad 403(b) plans. Unfortunately, Federal law is silent on this matter as is ERISA. The only provision in ERISA that remotely applies to this issue is that fiduciaries must act in the best interest of plan participants and beneficiaries for the exclusive purpose of providing retirement benefits.

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