September and October 2015 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

King & Spalding
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[author: Ryan Gorman]

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties. To avoid such penalties, employers should remain informed with respect to the filing and notice deadlines associated with their plans.

The filing and notice deadline table below provides key filing and notice deadlines for the next two months. If the due date falls on a Saturday, Sunday, or legal holiday, the due date is delayed until the next business day. Please note that the deadlines will generally be different if your plan year is not the calendar year. Please also note that the table is not a complete list of all applicable filing and notice deadlines (including any available exceptions and/or extensions), just the most common ones.

Deadline

Item

Action

Affected Plans

September 15
(8 ½ months after the end of the plan year)

Minimum Contribution Deadline

Deadline for plan administrator to contribute balance of minimum contributions necessary to avoid a funding deficiency.

Defined Benefit Plans

September 30 (within 9 months of the end of the plan year)

Summary Annual Report (SAR)

Deadline for plan administrator to distribute Summary Annual Report for prior year to participants and beneficiaries.  This deadline may be extended until 2 months following the close of the extension period for filing a Form 5500, if applicable.

Defined Contribution Plans

Health and Welfare Plans
(unfunded welfare plans are exempt)

September 30
(last day of the 9th month following the end of the prior plan year)

Certification of Adjusted Funding Target Attainment Percentage (AFTAP)

Deadline for actuary to certify AFTAP to avoid presumption that AFTAP is less than 60%.

 

Defined Benefit Plans

October 14

Medicare Part D Creditable Coverage Notice to Individuals

Deadline for employers that provide prescription drug coverage to Medicare Part D eligible individuals to provide a written disclosure notice to Medicare eligible individuals and their dependents covered under the plan indicating whether their prescription drug coverage is creditable coverage.

Health and Welfare Plans that provide prescription drug coverage to Medicare Part D eligible individuals

October 15
(2 ½ months after extension granted)

DOL Form 5500

Deadline for plan administrator to file Form 5500 for prior year if deadline was extended by filing a Form 5558.

Retirement Plans

Health and Welfare Plans

IRS Form 8955-SSA

Deadline for plan administrator to File Form 8955-SSA if deadline was extended by filing a Form 5558.

Retirement Plans

October 15
(9 ½ months after the previous plan year)

PBGC Premium Filing

Deadline for plan administrator of large plans (500 or more participants) to pay flat-rate or variable PBGC premium for current plan year.

Defined Benefit Plans with 500 or more participants

 

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