The end of the year is a time that many significant notices need to be distributed to retirement plan participants and also of compliance dates that must be met. This alert notes several key dates that will occur in late 2013 and early 2014. Please contact us if you are uncertain of the steps required to meet the various deadlines mentioned below. The dates below assume a calendar plan year.
December 1:
- Deadline for sending 401(k) safe harbor notice, if applicable.
- Deadline for sending Qualified Default Investment Alternative (QDIA) notice.
- Deadline for sending automatic contribution arrangement notice.
The three notices above may be combined for administrative convenience.
December 15:
- Deadline for sending Summary Annual Report to plan participants (assuming an extension was filed for the plan’s Form 5500).
December 31:
- Deadline for adopting all discretionary amendments reflecting plan changes implemented during the plan year.
- Deadline to adopt Section 436 amendments for calendar year defined benefit plans.
- Deadline to adopt or remove safe harbor status for the next plan year.
- Deadline for correcting failed ADP/ACP tests for the 2012 plan year.
- Deadline to allocate plan forfeitures (generally forfeitures are not to be carried over from one year to the next year).
January 31, 2014:
- Deadline for Cycle C plans to file for a favorable determination letter with the IRS. Generally affected are plans whose plan sponsor’s employer identification number (EIN) ends in a 3 or 8. Many governmental plans will file in Cycle C, unless they decide to file in Cycle E. Please contact us if you need assistance in determining whether you have made all required amendments to your plan in advance of filing.
- Deadline for distributing Form 1099-R to plan participants that received a distribution during 2013.