It’s the time of year when Plan Sponsors scramble to deliver the myriad notices required to be given to their participants. Even with the help of service providers, the sheer number of notices can be overwhelming. Below is a summary of the notices that may apply to a calendar year 401k plan.
Safe Harbor Notice – December 1st marks the deadline to distribute a notice of intent to use a safe harbor formula in the 2019 plan year. This notice must be provided to participants and plan beneficiaries no less than 30 days, but not more than 90 days, before the beginning of the plan year for which the election will apply.
Qualified Default Investment Alternative (QDIA) Annual Notice – Also due December 1st, regulations require a plan utilizing a default investment option to issue an annual notice to all active participants, former employees with account balances, and plan beneficiaries, who were previously defaulted into the QDIA and who have not subsequently directed the investment of their account. The notice must be delivered no less than 30 days prior to the beginning of the plan year.
Automatic Contribution Arrangement – If a plan offers either an eligible or qualified automatic contribution arrangement, commonly referred to as auto-enrollment, the employer must provide a notice explaining election options under the plan to all employees who are eligible to participate no less than 30 days, and no more than 90 days, prior to the beginning of each plan year.
ERISA 404(c) Disclosures – Due December 31st, the plan administrator must distribute notices to participants and beneficiaries if the employer wants to limit fiduciary liability for participant-directed investment decisions. If the decision to be covered by 404(c) is stated in the Summary Plan Description, this notice does not need to be distributed annually.
Fee Disclosure Notice – If not provided earlier in the year, December 31st is the last day to provide plan participants with the fee disclosure information required by ERISA 404a-5. The regulations require that plan participants and their beneficiaries receive an annual notice detailing information regarding the fees associated with the plan’s investments and any administrative service fees that are charged against participant accounts.
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