We are terminating our DC plan. We have a suspense account with forfeitures in it that we want to distribute to participants. The plan document is silent as to how to do this. What is the rule in how to allocate the forfeitures?

Thanks.

I assume the document calls for forfeitures to reduce the employer contributions? Solution: deem a contribution equal to the forfeiture amount.

You are correct that our document says that forfeitures reduce future employer contributions. Can you further explain how the deemed contribution would work?

Your forfeitures = x, you make a contribution of x. The contributions are reduced by the forfeitures, so no actual deposit of money is made to the plan.

... and then X (in the forfeiture account) is allocated to plan participants per plan provisions.