That’s surprise not in the serendipity sense.

Rather, you’ve just found out what’s wrong with the plan once it’s in the house. It could be one of a number of things. For example:

  • Plan document not current
  • Form 5500s not filed
  • History of late deposits
  • Loans in default
  • Eligibility rules not being followed

All of these are problems that can be readily fixed through one of the voluntary correction programs such as the Internal Revenue Service Employee Plans Compliance Resolution System (EPCRS); or the Department of Labor Voluntary Fiduciary Correction Program or Delinquent Filer Voluntary Compliance Program.

Better to find out before you take them over than after. Get your TPA involved sooner rather than later.

Jerry Kalish is President of National Benefit Services, Inc., a Chicago- based Third Party Administrator. He is the publisher of The Retirement Plan Blog. Jerry can be reached at

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