Upcoming Employee Benefit Plan Deadlines

August 4, 2016

This client alert follows up on our prior alerts entitled "Employee Benefit Plan Filing Deadlines." The following are the most common applicable filing deadlines (and/or "Heads Up" for coming deadlines) or other important dates for August and September 2016 for calendar year plans:

August 14 - (within 45 days after the close of the second calendar quarter) Deadline for a plan administrator to distribute benefit statements for the second quarter to participants who have participant-directed accounts in a defined contribution plan.

August 14 – (within 45 days after the close of the second calendar quarter) Deadline for a plan administrator for disclosing plan fees and expenses deducted from individual participant accounts in a defined contribution plan that has participant-directed accounts. Note that this can be done in the benefit statement described in the preceding deadline or as a standalone document.

August 15 – Deadline for tax-exempt trusts associated with qualified plans and VEBAS to file Forms 990 or 990-EZ with the IRS for the 2015 year if a three-month extension (for the May 15, 2016, deadline) was requested by filing a Form 8868.

August 30 – Deadline for a plan administrator of a defined contribution plan with participant-directed investments to distribute required annual investment comparative chart (unless the plan administrator has timely elected to switch to a different filing deadline). 

September 15 – Deadline for plan administrators to make remaining balance of minimum contribution to defined benefits plans to avoid funding deficiency.

September 30 – Deadline for actuary to certify Adjusted Funding Target Attainment Percentage (AFTAP) for defined benefit plans to avoid presumption that AFTAP is less than 60 percent.

September 30 – Deadline for plan administrators of defined contribution plans and certain health and welfare plans to provide participants a summary annual report of the Form 5500 filed on July 31, 2016. If a Form 5500 is filed under an extension, the SAR must be distributed within two months following the expiration of the extended deadline for filing the Form 5500.

Heads up on upcoming deadlines:

  • Plan administrators with EINs ending in "1" or "6" with individually designed qualified plans should make its last Cycle A filing for a favorable determination letter by January 31, 2017. These plan administrators will want to begin their restatement of their plans and complete the related IRS forms soon.
  • With respect to upcoming open enrollments, plan sponsors of health plans must provide a summary of benefit and coverage (SBC) to participants with enrollment materials, or, if the plan sponsor does not have an open enrollment, 30 days prior to the beginning of a plan year.
  • Any discretionary amendments to qualified plans must be adopted and signed by December 31, 2016. Plan sponsors who want to make any such amendments should have them on the drawing board soon.

Please note that there are other deadlines which apply to the distribution of documents and notices to employees upon their employment or their termination of employment which are not addressed in this alert. If you have any questions regarding the deadlines listed in this alert or any other compliance deadlines, please contact Donald S. Kohla at 678.336.7140 or Jan G. Marsh at 678.336.7135.

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