Uncashed checks can be an administrative headache for retirement plans, potentially raising fiduciary and compliance concerns. Why?...more
The focus of the US Department of Labor (DOL) on missing participants and uncashed checks (discussed in our LawFlash DOL Guidance on Missing Participants Is No Longer Missing) recently began expanding into the area of...more
Retirement plan administrators can run into issues with uncashed distribution checks, most often when those distributions are mandated as required minimum distributions under the Tax Code. Last month, the IRS issued Revenue...more
In a recent revenue ruling, the IRS stated that if a participant or a beneficiary doesn’t cash a distribution check in the year it was issued, the individual still must include the amount in gross income for that year....more
On August 14, 2019, the IRS issued Revenue Ruling 2019-19, providing guidance to both tax-qualified plan administrators and participants on the tax treatment of plan distribution checks that are not cashed. ...more
A problem faced by the administrators of 401(k) and other retirement plans is what to do about plan participants who fail to cash distribution checks. This problem arises most commonly in connection with a plan that is...more
In the retirement plan industry, we have rules and we have guidelines on what to follow. However, there is one gray area that the Department of Labor (DOL) has absolutely no guidance: uncashed checks....more