PLANSPONSOR - November/December 2024 - 35

November
14 Deadline for participant-directed DC plans to provide participants
with a quarterly benefit/disclosure statement and statement
of plan fees and expenses charged to individual planaccounts
during Q3. (Due 45 days after the end of the quarter.)
15 Summary annual reports due to participants if the Form 5500
deadline was extended due to a corporate tax filing extension.
December
1 Final deadline to disseminate the 401(k) safe harbor annual
notice to plan participants.
1 Final deadline for supplying the QDIA annual required
notice to all participants who were defaulted into a QDIA
no more than 30 days prior to the beginning of the plan
year.
1 Final deadline to provide participants with the annual automatic
enrollment and default
investment notices;
may be combined with the QDIA notice.
1 Deadline to elect safe harbor status for the current plan year
with nonelective contributions if the nonelective contribution
is less than 4% of compensation.
these
15 Extended deadline for providing summary annual reports to
participants if the Form 5500 deadline was extended because
of filing Form 5558.
31 2025 RMDs are due to participants who were age 73 or older
on or after January 1, 2023.
31 Deadline for correcting a failed ADP/ACP test.
31 Deadline to adopt discretionary amendments to the plan,
subject to certain exceptions-e.g., anti-cutbacks.
31 Deadline for a safe harbor plan to remove its safe harbor
status for the following year or for an existing DC plan to
convert to a safe harbor plan.
31 Deadline to elect safe harbor status for the prior plan year with
a nonelective contribution of 4% or more of compensation.
*If a traditional safe harbor 401(k) plan provides a nonelective
contribution but also non-safe-harbor matching contributions
structured so the plan need not satisfy the ACP test, then the plan
still must satisfy the safe harbor notice requirements. If a 401(k)
plan that satisfies the safe harbor nonelective contribution requirements
also provides non-safe harbor matching contributions and
must satisfy the ACP test, then the plan need not satisfy the safe
harbor notice requirements.
the
Plan Sponsor Duties Without Dates
Reviewing and editing by Summer Conley, a partner in the Los Angeles office of Faegre Drinker Biddle & Reath LLP, and Kristina Ferris
Salamoun, an associate in the firm's Washington office.
D
efined contribution plan statements
must be provided at least annually for
participants who do not have the right to
direct their investments, and at least quarterly
for those who do have the right.
A qualified default investment alternative
notice for plans that choose to use a
QDIA must be provided to participants 30
days prior to their first investment. Note: If
the plan has immediate eligibility, participants
must be given the notice as soon as
administratively feasible.
Notice to participants of a qualified
automatic enrollment arrangement or an
eligible
automatic
enrollment
arrangement,
and of a participant's ability to opt
out, must be provided 30 days prior to eligibility
and then annually. For plans with
immediate eligibility, notice may be given
on or as soon as feasible after eligibility.
Defined benefit or money purchase
pension plans must provide the Pension
Benefit Guaranty Corporation with a notice
of failure to meet minimum funding standards
within 60 days of a missed payment
or denial of payment waiver.
An explanation of a plan's pre-retirement
survivor annuity must be provided
to a participant between the first day of
the plan year in which she reaches age
32 and the last day of the plan year in
which she reaches 35. If a participant is
over 35 when hired, she should be given
the explanation within one year of hire.
An explanation of a joint and survivor
annuity must be made to affected plan
participants between 90 and 30 days
before the annuity's starting date.
Participant Fee Disclosures
Plan sponsors must furnish fee disclosures
to participants on or before the date
on which they or their beneficiary may first
direct their investments in the plan and at
least
annually
thereafter-now defined
as " at least once in any 14-month period,
without regard to whether the plan operates
on a calendar year or fiscal year basis. "
Sponsors must, at least quarterly,
supply participants with a statement of
account expenses and the services for
which they apply. If any change is made to
fee information, the sponsor must inform
participants 30 to 90 days beforehand.
PLANSPONSOR.COM November - December 2024 35

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PLANSPONSOR - November/December 2024

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