SECURE 2.0 introduced many changes for retirement plans, including updated disclosure requirements for a defined benefit plan’s annual funding notice (AFN). These updated AFN disclosure requirements apply for all plan years beginning after December 31, 2023. For calendar-year defined benefit plans, the first AFNs subject to the revised requirements will be due by April 30, 2025.[1]
Prior to SECURE 2.0, AFNs were generally required to contain information about the plan’s funded status, investment policies, regulatory filings, participant demographics, and other key information to ensure transparency and compliance. Though the goal of keeping relevant parties informed through AFNs remains the same, some of the requirements for the specific information to be included have changed, including:
Plan sponsors should carefully review the required changes under SECURE 2.0 when preparing AFNs for defined benefit plans with plan years beginning after December 31, 2023. There is currently no updated model notice from the Department of Labor, though a model incorporating the SECURE 2.0 changes could be released prior to April 30, 2025.
[1] Most defined benefit plans that are covered by the Pension Benefit Guaranty Corporation (PBGC) are required under ERISA § 101(f)(3) to send out an AFN to participants for each plan year within 120 days after the end of the plan year.
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