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Time to Prepare for the End of the Year

(Part One)

9.11.2017

The end of the year is rapidly approaching! To avoid costly penalties that can arise from inadvertent errors in the year-end rush, plan sponsors should begin talking with their service providers now about what must be done by year-end.

Retirement Plan Disclosures

As a quick reference, the following is a list of certain year-end disclosure requirements for retirement plans:

  • 401(k) safe harbor notice – to be distributed to participants 30-90 days prior to the beginning of each plan year; by December 1, 2017 for calendar year plans. The same deadline applies to traditional safe harbor plans and qualified automatic contribution arrangement (QACA) safe harbor plans.
  • Automatic contribution arrangement (ACA) notice – to be distributed to participants 30-90 days prior to the beginning of each plan year; by December 1, 2017 for calendar year plans. The same deadline applies to plans with plain ACAs and eligible automatic contribution arrangements (EACAs).
  • Qualified default investment arrangement (QDIA) notice – to be distributed to participants 30-90 days prior to the beginning of each plan year; by December 1, 2017 for calendar year plans.
  • Annual participant fee disclosure documents – ERISA plans must provide an annual fee disclosure at least once in each 14-month period. If you distributed the fee notice with your other notices toward the end of last year, plan to do so again this year.
  • Summary annual report (SAR) – ERISA-covered defined contribution plans must provide the SAR to participants within 9 months of the end of the plan year or 2 months after the Form 5500 filing deadline. For calendar year plans, this means the SAR is due September 30 if the Form 5500 was not extended or December 15 if the Form 5500 was extended.

Keep in mind that vendor-prepared and distributed notices are often computer-generated and may not accurately reflect special features of your plan. Ineffective or incorrect notices may result in confusion among your participants as well as errors and penalties. Be sure to review all notices carefully and address any concerns or questions with your benefits counsel.

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