How should records on terminated participants be handled? Must they be considered plan participants and should schedule SSA be included with a plans Form 5500 filing?
There is no guidance from the DOL on this, so each plan administrator must decide how to handle terminated employees. Usually the determination of who is a participant is relatively clear-cut. If the plan continues to hold assets to fund the benefits to be paid to a terminated employee, then that employee must be considered a plan participant for purposes of Form 5500. However, in the case of defined contribution plans funded with TIAA-CREF contracts, the question of whom to include in a plan filing becomes a little more complicated, as explained below. Under the TIAA-CREF system, many rights are vested in the individual participant. Unlike plans that are funded through a trust, individual participants in plans funded with TIAA-CREF contracts already own their own contracts. This is generally true even for participants covered under our group annuity contracts because under those contracts the participants own their own individual certificates. After an employee terminates employment,
Related Questions
- How should records on terminated participants be handled? Must they be considered plan participants and should schedule SSA be included with a plans Form 5500 filing?
- I plan to conduct this survey, but my Project and/or Visitor Center is not included in the Survey Schedule Generator for Visitor Centers. How do I proceed?
- How are refunds handled for participants in the TuitionPay payment plan?
