I recently found some IRAs that were opened without IRA plans. This means that customers did not receive a custodial agreement or a 5305-A at account opening. Some of the accounts are set up as POD rather than beneficiaries with percentages. Have we broken rules or laws due to not providing the named documents? Do we need to just close the accounts and open up plans and do an internal transfer of the funds so that customers can get all updated and corrected IRA disclosures? If not, do we just try to maintenance the accounts so they show beneficiaries rather than POD or is that not necessary? They did receive TIS (a CD TIS, but they basic information was there).
Any help is welcomed.