To help protect plan participants from fraud, American Trust is placing additional requirements on distribution forms received from our clients. The new Requirements include:
Signature Date Requirements:
- The participant signature must be first (meaning the PS/TPA signature(s) are on the day of or after the participant signature date).
- All signatures must be within the last 180 days.
- Residual only distributions after the balance had been cleared out (dividends, additional contribution, etc.) can use the original form if within 180 days (six months) of the original distribution processing date.
Signature Requirements for Distributions and Loan Requests:
- Full Service Plans:
- Participant signature can be a wet signature or electronic signature; we do not need an e-signature code or audit trail if it is an electronic signature.
- Plan Sponsor signature can be a wet signature or electronic signature, and we do need an e-signature code or audit trail if it is an electronic signature.
- For Plans with an Outside TPA:
- Participant signature can be a wet signature or electronic signature; we do not need an e-signature code or audit trail if it is an electronic signature.
- Plan Sponsor signature can be a wet signature or electronic signature, but we do not need an e-signature code or audit trail if it is an electronic signature.
- TPA signature can be a wet signature or electronic signature, and we do need an e-signature code or audit trail if it is an electronic signature.
For Incoming Rollover Forms:
- Participant signature can be a wet signature or electronic signature; we do not need an e-signature code or audit trail if it is an electronic signature.
- Plan Sponsor signature can be a wet signature or electronic signature, and we do need an e-signature code or audit trail if it is an electronic signature.
New streamlined distribution forms are in the works and will be rolled out soon. The forms should be easier for plan participants to follow and complete.
For ACH Authorization Forms (no change based on recent requirements):
- Approver signature can be a wet signature or electronic signature, with both an e-signature code and audit trail if it is an electronic signature, as required by Mid Atlantic.