August and September 2014 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

by 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 and excise taxes. To avoid such penalties and excise taxes, employers must 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 common to calendar year plans for the next two months. Please note that the deadlines will be different if your plan year is not the calendar year. Please also note that the table does not include all applicable filing and notice deadlines, just the most common ones. King & Spalding is happy to assist you with any questions you may have regarding compliance with the filing and notice requirements for your employee benefit plans.

Deadline

Item

Action

Affected Plans

August 14 (within 45 days after the close of the second quarter of plan year)

Benefit Statements for Participant-Directed Plans

Deadline for plan administrator to send benefit statement for the second quarter of the plan year to participants in participant-directed defined contribution plans.

Defined Contribution Plans with participant-directed investments

 

Quarterly Fee Disclosure

Deadline for plan administrator to disclose fees and administrative expenses deducted from participant accounts during the second 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.

 

August 15 (the 15th day of the 8th month after the end of the plan year)

IRS Forms 990 and 990-EZ

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 3-month extension by filing a Form 8868.

Qualified Retirement Plans*

Voluntary Employee Beneficiary Associations

August 30

Comparative Chart of Investment Alternatives

Deadline for plan administrator to furnish the 2014 comparative chart of investment alternatives, unless plan administrator takes advantage of a one-time delay to align the timing with that of other plan enrollment materials. Note that the plan administrator may take advantage of the delay in 2013 or 2014, but not in both years.

Defined Contribution Plans with participant-directed investments

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 22

Updated Business Associate Agreements (BAA)

Deadline to amend grandfathered BAAs to comply with the HIPAA compliance rules published January 25, 2013.

A grandfathered BAA was entered into before January 25, 2013 and was not renewed or modified from March 26, 2013 to September 23, 2013. Note that if the grandfathered BAA is renewed or modified on or after September 23, 2013, it must be amended at the date of such renewal or modification.

Grandfathered BAAs associated with Health & Welfare 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 & 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

* Qualified Retirement Plans include all defined benefit and defined contribution plans that are intended to satisfy Code §401(a)

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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