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PLAN DISTRIBUTIONS: It Is Time to Implement Procedures to Minimize Uncashed Checks
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Journal Article
PLAN DISTRIBUTIONS: It Is Time to Implement Procedures to Minimize Uncashed Checks
2020
Overview
[\"61st Annual Survey of Profit Sharing and 401(k) Plans,\" Plan Sponsor Council of America, available at https:// www.psca.org/61st_AS, (retrieved November 2019)] Automatic enrollment, deferral escalation, and generous employer matching contributions have increased plan participation and boosted savings. [...]Revenue Ruling 2019-19 clarified three key issues related to required distributions that are received and remain uncashed [\"Rev. Rul. 201919 Failure To Cash a Distribution Check From a Qualified Retirement Plan,\" Internal Revenue Service, available at https://www. irs.gov/pub/irs-drop/rr-19-19.pdf (retrieved November 2019)] 1.The ruling confirmed the doctrine of constructive receipt. [\"ERISA Advisory Council: Permissive Transfers of Uncashed Checks from ERISA Plans to State Unclaimed Property Funds,\" Michael L. Hadley, Davis & Harman LLP, available at https:llwww.dol.govlsitesldolgovlfileslEBSAlabout-ebsal about-uslerisa-advisory-councill2019-permissive-transfersof-uncashed-checks-from-erisa-plans-to-state-unclaimedproperty-funds-hadley-davis-and-harman.pdf (June 26, 2019)] Plan Sponsors May Be Able To Reduce or Eliminate the Majority of Uncashed Checks Revenue Ruling 2019-19 failed to clarify how plan sponsors and administrators should handle issues related to uncashed checks that are not received by participants (or offer guidance about how to determine whether checks are received). [\"ERISA Advisory Council: Permissive Transfers of Uncashed Checks from ERISA Plans to State Unclaimed Property Funds,\" Michael L. Hadley, Davis & Harman LLP, available at https:llwww.dol.govlsitesldolgovlfileslEBSAI about-ebsalabout-uslerisa-advisory-councill2019-permissivetransfers-of-uncashed-checks-from-erisa-plans-to-stateunclaimed-property-funds-hadley-davis-and-harman.pdf (June 26, 2019)] Plan sponsors that do not have the time or resources to conduct searches may opt to outsource the process. * Improving participant communications.
Publisher
Aspen Publishers, Inc
Subject
