Good morning,
Thank you for your inquiry. Please see guidance below:
1. For each transfer, should the shares be counted as part of the Contributory IRA's holdings up to the moment of transfer, and then as part of the Roth IRA's holdings from that moment forward (i.e., treated like a continuous holding period that simply moved custodial "location" mid-stream)? Confirmed.
2. Alternatively, should the full block of transferred shares be attributed only to the receiving account (the Roth IRA) for the entire Class Period, with the Contributory IRA's Class Period position calculated as though the transferred shares were never held there? See above. You would enter the shares when purchased in the first account, the transfer in the sales/free deliveries transactions section on the transfer date, and then the shares entering the second account on the purchases/free receipts section for the second account's claim.
3. Does the Plan of Allocation's treatment of purchase price and date (e.g., for FIFO/LIFO or 90-day look-back calculations) carry over across the transfer using the original acquisition cost and date in the Contributory IRA, or does the Roth IRA's cost basis and holding period reset to the transfer date? The purchase date and price are entered on the claim form for the Contributory IRA, while on the Roth IRA claim form, the shares entering the account from the in-kind transaction should bear the date that they were transferred and a value of $0.00. The share damages are calculated based on the purchase information in the original purchasing account, and the sale or holding (as applicable) of those shares are in receiving account will be used for the FIFO matching in the calculation of damages (if any) in the account where the shares were originally purchased.
4. Is there a preferred way to document in-kind transfers of this kind on the Claim Form or in supporting schedules (for example, a note or supplemental schedule identifying the transfer dates and share counts), so that the transferred shares are not inadvertently counted twice or omitted entirely from the settlement calculation? The Contributory IRA will have the date of the transfer out, number of shares and a value of $0.00 and the receive into the Roth IRA will have the transfer in date, number of shares, and value as $0.00. You will want to provide the proof/supporting documentation showing shares leaving the first account and entering the second for those claims.
If you have any further questions, please feel free to contact our office.
Thank you.
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Claims Administrator
Strategic Claims Services, Inc.
600 N. Jackson St. - Suite 205
Media PA 19063
Phone: 610-565-9202
Fax: 610-565-7985
Toll Free: 1-866-274-4004
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