With the newest legislation, it is now possible for participants to transfer their IRA's (SIMPLE, SEP, traditional, etc) into a 401k plan. I see many providers already have a transfer form out on this.

What reporting requirements are necessary for this? Presuming a plan sponsor pools all assets into a retail investment account and act as trustee (and no custodian). Do these assets continue to be tracked as IRA assets? or simply as transferred in assets that are fully vested? What, if any, reporting is required by the sponsor (again, remember there is no custodian).

please advise...

Related proposed reg's can be found at http://benefitslink.com/taxregs/deemed_ira...prop_2003.shtml

Looks like they are soliciting comments untill the end of July, with final reg's to follow.

- JCatt

There are two different types of transfers. You can transfer from an IRA to a 401(k). Those assets become part of the 401(k), just like a rollover from another plan, and no longer have anything to do with an IRA. The proposed regulations have nothing to do with this transaction.

Or, a 401(k) can create "deemed IRA" accounts which can be annually contributed to or have other assets (rollovers from other plans or another IRA) transferred to it. The regulations only address creating the deemed IRA, they do not address transfer issues. There is also a lengthy regulation from EBSA on deemed IRAs. There is expected to be a lot more coming out, because the IRS and EBSA proposed regulations did not cover nearly enough of the perceived problems in order to properly set these up.

to add to the first post, can a participant roll a roth IRA account into a traditional 401(k) plan if the plan allows for rollovers?