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Monday, November 26, 2012

Year-End 401(k) Plan Disclosures: Upcoming Deadlines

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Having distributed the first set of fee disclosure documents this summer and initial quarterly statements of plan fees and expenses this fall, it's time for 401(k) plan administrators to turn their attention to recurring year-end disclosure requirements. Upcoming deadlines include:

  • Notice of automatic enrollment must be provided at least 30 days and no more than 90 days before the beginning of the 2013 plan year (December 1, 2012, for calendar year plans).
  • The annual qualified default investment alternative (QDIA) notice also must be furnished at least 30 days before the beginning of the plan year (December 1, 2012, for calendar year plans).
  • Plans designed to satisfy safe harbor nondiscrimination requirements must provide safe harbor notices between 30 and 90 days before the beginning of the 2013 plan year (December 1, 2012, for calendar year plans).The safe harbor notice may be combined with the QDIA notice.
  • Quarterly benefit statements (including a statement of plan fees charged to the participant's account, if applicable) are due 45 days after the end of the next quarter (February 14, 2013, for calendar year plans).

Due to the new fee disclosure rules, some participants may see charges deducted from their quarterly benefit statements. Have plan administrators seen any participant reaction to these disclosures?

--Vanessa Walts

Tax Law Editor (Compensation Planning)

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