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Deadline
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Item
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Action
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Affected Plans
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November 1 (by the first day of open enrollment)
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Summary of Benefits and Coverage for Health Plans that Require Reapplication
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Deadline for group health plan administrator (for self-insured plans) or group health plan administrator or insurer (for fully insured plans) to provide a Summary of Benefits Coverage (SBC) if participant application is required for renewal.
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Group Health Plans and Health Insurance Issuers
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November 14
(within 45 days after the close of the third quarter)
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Benefit Statements for Participant-Directed Plans
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Deadline for plan administrator to send benefit statement for the third quarter of the plan year to participants in participant-directed defined contribution plans.
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Defined Contribution Plans with participant-directed investments
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Quarterly Fee Disclosure
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Deadline for plan administrator to disclose fees and administrative expenses deducted from participant accounts during the third quarter of the plan year. Note that the quarterly fee disclosure may be included in the quarterly benefit statement or as a stand-alone document.
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November 15
(the 15th day of the 11th month after the end of the plan year)
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IRS Forms 990 and 990-EZ
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Deadline for tax-exempt trusts associated with qualified retirement plans and voluntary employee beneficiary associations (VEBAs) to file Forms 990 or 990-EZ with the IRS for prior year if the trustee obtained a second 3-month extension by filing a Form 8868.
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Qualified Retirement Plans*
Voluntary Employee Beneficiary Associations
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December 1 (at least 30 but no more than 90 days before the beginning of the plan year)
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Safe Harbor Notice
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Deadline for plan administrator to distribute a notice of intent to use a safe harbor formula to participants and beneficiaries. This notice must be provided within a reasonable period of time before the beginning of the plan year. The regulations provide a safe harbor of not less than 30 days but not more than 90 days before the beginning of the plan year.
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401(k) and
401(m) Plans
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Contingent Safe Harbor Notice
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Deadline for plan administrator to distribute a notice to participants and beneficiaries specifying that the plan may be amended during the following plan year to include a 3% employer non-elective safe harbor contribution.
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401(k) and 401(m) Plans
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Auto-Enrollment Notice
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Deadline for plan administrator to provide annual auto-enrollment notice for plans with qualified automatic contribution arrangements (QACA) or eligible automatic contribution arrangements (EACA). This notice must be provided sufficiently early so that the employee has a reasonable period of time after receipt to make QACA or EACA elections. The preamble to the regulations notes that this timing requirement is deemed to be satisfied if the notice is given at least 30 days but not more than 90 days before the beginning of each plan year.
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401(k) Plans with QACA or EACA
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December 1 (at least 30 days before the end of the plan year)
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Qualified Default Investment Alternative (QDIA) Annual Notice
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Deadline for plan administrator to provide annual QDIA notice to participants or beneficiaries.
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Defined Contribution Plans with participant-directed investments
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Safe Harbor Follow-Up Notice
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Deadline for plan administrator to distribute a notice to participants and beneficiaries informing them that the 3% employer non-elective safe harbor contribution will be made for the current plan year. This notice may be combined with the Contingent Safe Harbor Notice for the following plan year.
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401(k) and 401(m) Plans
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December 1
(at least 30 days prior to the first day of the new plan or policy year)
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Summary of Benefits and Coverage for Health Plans that Automatically Renew Coverage
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Deadline for group health plan administrator (for self-insured plans) or group health plan administrator or insurer (for fully insured plans) to provide a Summary of Benefits Coverage (SBC) if coverage automatically renews each year.
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Group Health Plans and Health Insurance Issuers
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December 1 (no later than 30 days before participant becomes eligible to diversify employer stock)
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Diversification Notice
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Deadline for plan administrator to provide diversification notice to participants who will first be eligible to divest employer securities on January 1.
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Defined Contribution Plans with participant-directed investments in employer stock
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December 15 (2 months after the extension for filing Form 5500)
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Summary Annual Report
(SAR)
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Deadline for plan administrator to distribute SAR for prior year to participants and beneficiaries, if the IRS granted a 2-month extension for Form 5500 on or before the original Form 5500 deadline.
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Defined Contribution Plans
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December 31
(last day of plan year following plan year for which contributions were made)
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Correction of Excess Contributions & Excess Aggregate Contributions
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Deadline for plan administrator to make corrective employer contributions or distribute excess contributions (ADP test failure) and excess aggregate contributions (ACP test failure) for the prior year.
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401(k) and
401(m) Plans
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December 31
(last day of plan year)
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Code §436 Benefit Restrictions Amendment
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Deadline for plan sponsor to add benefit restriction provisions to plan as required by Code §436. Note that while the benefit restrictions apply to underfunded plans, all affected plans, regardless of funded status, must add the provisions to the plan as provided in Code §436.
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Defined Benefit Plans
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Discretionary Amendments
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Deadline for plan sponsor to adopt discretionary plan amendments.
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Qualified Retirement Plans
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Adjusted Funding Target Attainment Percentage (AFTAP) Certification
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Deadline for actuary to certify a specific AFTAP if a range certification was previously issued.
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Defined Benefit Plans
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December 31 (at least annually)
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ERISA §404(c) Disclosures
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Deadline for plan administrator to distribute notices to participants and beneficiaries if the employer wants to limit fiduciary liability for participant-directed investment decisions.
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Defined Contribution Plans with participant-directed investments
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Annual Fee Disclosure to Participants
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Deadline for plan administrator to make annual disclosure of certain fees for participant directed individual account plans to be provided to participants and beneficiaries.
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Pension Benefit Statements
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Deadline for plan administrator of a defined benefit plan using alternative notice for pension benefit statements to notify participants of availability of a pension benefit statement and instructions on how to obtain it.
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Defined Benefit Plans
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December 31
(at least annually as a part of any yearly informational packet)
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WHCRA Notice
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Deadline for group health plans to distribute Women's Health and Cancer Rights Act (WHCRA) notice for new plan year to all participants and beneficiaries advising them of available mastectomy benefits under WHCRA and any deductibles and co-insurance limits applicable to such benefits.
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Health and Welfare Plans
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Children's Health Insurance Program Reauthorization Act (CHIPRA)
Notice
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Deadline for employer to notify employees of potential opportunities for premium assistance from the state in which the employee resides.
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Group Health Plans in states that provide premium assistance under Medicaid or CHIP
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December 31
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Required Minimum Distributions
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Deadline for plan administrator to distribute current year's required minimum distributions under IRC §401(a)(9).
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Qualified Retirement Plans
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Correction of 403(b) Plan Document
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Deadline for 403(b) plan sponsors to take advantage of 50% fee discount for VCP submission relating to the late adoption of a written plan document. Note that the late adoption of a written plan document must be the only failure identified in the VCP submission in order to receive the discount.
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403(b) Plans
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