Navigating the Distribution Correction Minefield

One of the more challenging aspects of retirement plan administration is compliance with the numerous distribution rules. Because of the numerous distribution rules, the opportunity for a mistake is high. Fortunately, most distribution failures are operational and the employer can self-correct the failures. Unfortunately, EPCRS provides few correction methods for distribution failures, leaving practitioners to formulate their own corrections. The issue that makes distribution corrections even more difficult is taxation. Correction of a distribution failure may not change the taxation. In this meeting, we will address the more difficult failures and provide recommended correction methods for the failures.

• Required minimum distribution failures – three correction options
• Overpayment
• Underpayment
• Failure to provide the proper distribution notice
• Failure to obtain participant/spousal consent for a distribution
• Delayed distributions
• Distribution prior to a distributable event (too early)
• Discriminatory availability of a distribution option
• Prohibited discretion over distribution options
• Rollovers vs. Transfers
• Required distributions

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