On a daily basis we receive new distribution requests that need to be reviewed by our Transactions department and prepared for Sponsor Approval. Distribution requests may be entered on MyPlanConnection.com by participants or participant service specialists, or they may be requested via paper form. 

New distributions show up in PlanConnect under Tasks > Distributions with a blank template that includes only:

• Participant's Name
• SSN
• PlanID
• Request Date

Transaction specialists must then complete the Review tab under each distribution request. To find distributions that have not been reviewed, specialist must search for distributions that have a Review Start Date = Null. Note the following requirements to review distributions;

Paper Forms

• Requests over $500.00 require notarized signature
• Requests over $250,000 require DL

Electronic Requests

• Requests over $250,000 require DL

With these criteria in mind, the following steps are taken to review distributions:

Additional Notes for In-Service and other distribution types will be at the bottom of this article. 

1. Download trading instructions for this request from the following directory: R:\CAPITALOperations\Distributions\Cover Sheets. Trading instructions contain relevant information pertaining to this request, which will help determine if certain criteria is met for the distribution.
2. Review Admin Requirements
   1. Select Submission Type (Paper vs. Web)
   2. Review All Pages Received (N/A for Web requests)
   3. Review All info Rec'd (N/A for Web Requests)
   4. Review Form Signed (N/A for Web Requests)
   5. Review Job Status (Is participant terminated and requesting a termination distribution?)
   6. Review Vesting (Does the EE's sources look correct based on the vesting schedule)
      1. If vesting % appears to be incorrect, research further by reviewing plan document, checking conversion records in client folder, or by engaging the plan admin or conversions.
         For assistance in researching vesting discrepancies, please see this article: https://bluestarretirement.freshdesk.com/a/solutions/articles/33000293634?lang=en&portalId=33000059188
3. Once all necessary boxes are completed, the Review Complete box will populate automatically. If this box is not populated, review requirements to find missing item and work to correct it based on what may be needed.
4. Review Security Requirements
   1. Is a picture ID required? Review requirements noted above. IDs may be submitted along online request, so you may review the Document Vault for uploads. If ID has been received, does the name match our records? Is the ID still valid? If not, further information would be required from participant before we should proceed.
   2. Is a notary required? If a notarized signature was received, confirm if notary's cert is still valid.
   3. Does the address on the form match the address on record (N/A for web requests)
   4. Does the request require manager approval? (Cash requests over $75,000 and rollovers over $200,000 require approval)
5. Complete Trading Instructions
   1. Enter gross amount if not lump sum (N/A for web requests)
   2. Enter Source if source specific (rare)
   3. Enter delivery method if specified. Default is always standard mail.
   4. Update tax information if applicable.
   5. If applicable, mark as 2nd Distribution for reduced fee if cover sheet indicates this is a second distribution. Please note this only applies to a second termination distribution, not in-service/hardship requests.
   6. Write 1099 Code under other instructions
6. Once the review is complete, upload the Trading Instructions to the documents tab of the PC record.
7. Complete final check of Details tab to ensure all appropriate fields are updated before moving onto the next request.

Additional Considerations when reviewing distribution and eligibility

Required Minimum Distributions: Participants over the age of 73 who are either terminated or active/5% owner may be due their Required Minimum Distribution. If the participant is processing a full rollover out of the plan, this must be issued along the rollover request. A DMC alert must be added with the RMD amount and the participant should be notified this will be processed. Full instructions here for calculating the amount due: https://bluestarretirement.freshdesk.com/a/solutions/articles/33000283929?lang=en&portalId=33000059188

Money Purchase Sources: Participants who have Money Purchase money in their account must provide a Joint-Survivor and Annuity form signed/notarized by their spouses (form attached), or provide confirmation that they are not married. You will need to send an email to the participant with the J&S form attached (canned response available, see FD 845524 for example of communication) and note the PC record with the FreshDesk ticket number. The PC record should also be updated to ensure automated notifications are sent out to the participant, example below:

In-Service Distributions by Web: To find out whether an in-service withdrawal is a rollover or a taxable withdrawal, transaction specialists must look at MyPlanConnection.com, under the plan's approval page, and payment detail page, to see the instructions for payment. This will help determine the correct 1099 code. 

Status Notes/DMC Alerts: CSRs or other internal associates may add a status note or DMC alert to request special handling. We should be mindful to check these notes during the cover sheet review to ensure any requested changes can be accommodated or if additional documentation may be needed from the participant. For example, if a DMC alert has been added requesting an alternate mailing address, we should check to confirm address verification has already been received/uploaded. If not, we will need to request this from the participant.