Year-End Deadlines for Retirement Plans
Before we can officially wrap up the end of 2015, there are a few important administrative tasks to take care of in Q4. Follow our guide below of common deadlines and notices. Please note, these are intended for single employer calendar year-end plans and some notices and deadlines may not apply to your particular plan.
Deadline to request RMDS– Do you have employees who are 70.5 or older? Be aware of participants who need to take required minimum distributions from the plan. Work with your TPA in November to begin the distribution process. Read more about RMDs here.
Discretionary plan amendments- This is a great opportunity to make any amendments to the plan, especially in 2015 during the mandatory restatement cycle. Call your TPA to discuss the changes you’ve been considering making in your qualified retirement plan.
Notices to Distribute to Employees by December 1st
Safe Harbor Notice– For plans that have a Safe Harbor 401(k) feature, all employees must receive a Safe Harbor notice, even if they aren’t participating in the plan, at least 30 days before the beginning of the plan year. For calendar year-end plans, this deadline is December 1, 2015. For odd year plans, the deadline is 30-90 days before the beginning of the new plan year.December 1st is also the deadline to request to amend, to add, or to remove Safe Harbor status for the following year.If amending, plan sponsors must notify participants 30-90 days in advance.
Automatic Enrollment Notice– For plans that have an automatic enrollment feature, plan sponsors must provide eligible employees with notice 30 days before the first of the plan year. For calendar year-end plans this is December 1, 2015.
QDIA Notice– Qualified Default Investment Alternative, a notice to participants must be given if they are invested by default in the QDIA. With this feature, when participants fail to make investment elections, plan sponsors can enroll participants into a “default” investment.
The Safe Harbor Notice, Automatic Enrollment Notice, and QDIA can all be merged into a single notice.
QACA Notice– Qualified Automatic Contribution Arrangement notice must be provided within a reasonable amount of time before the beginning of the plan year. This feature automatically increases participants’ contribution amounts each year. The notice explains the employees’ rights to stop or change their 401(k) deferral percentage.
Deadline to request amendments in SPD for following year– if amending, must notify participants 30-90 days in advance.
SAR– For plans that filed an extended 5500 form, their SAR Summary Annual Report is due December 15th. If the Form 5500 was filed by July 31st, then the deadline is September 30th. The SAR is a financial report that summarizes the plan information for the participant and must be distributed each year.
December 31st Deadlines
Deadline for processing corrective distributions for failed ADP/ACP test with 10% excise tax.
Deadline for correcting a failed ADP/ACP test with qualified non-elective contributions (QNEC).
Required Minimum Distributions due (RMD’s)- If you have employees age 70.5 they may have to take a required minimum distribution before the end of the year.
Deadline to amend plan for discretionary changes for the following plan year- Have you considered changing some elements of your plan? In order for those changes to take effect in January 2015, you must implement them before the end of 2015.