Employee Benefit Plan Filing Deadlines

March 26, 2015

This alert follows up on our previous alert on February 13, 2015, titled "Upcoming Filing Deadlines," regarding upcoming employee benefit plan deadlines. The following deadlines are the most common deadlines applicable generally to calendar year plans for April, May and June.

• April 1: Deadline for distributing prior year's required minimum distributions for participants who reached age 70 and a half or older and terminated employment in 2014. Note distributions are also due to a five percent owner who reached age 70 and a half or older in 2014 even if such owner is still employed.

• April 15: Deadline for filing 2014 financial and actuarial information with the PBGC for certain defined benefit plans.

• April 15: Deadline for refunding excess deferrals made to 401k plans and excess contributions made to IRAs for 2014.

• April 30: Deadline for providing an annual plan funding notice to participants, beneficiaries and participating unions in defined benefit pension plans (with more than 100 participants) and to the PBGC (if underfunding is $50 million or more or upon request).

• May 14 (within 45 days after the close of the first quarter): Deadline for providing first quarter 2015 statements to participants on fees charged to their "self-directed" accounts in a defined contribution plan.

• May 14 (within 45 days after the close of the first quarter): Deadline for providing first quarter 2015 statements to participants who have "self-directed" accounts in a defined contribution plan.

• May 15 (within four and a half  months after the end of the plan year, unless a 90-day extension was requested by filing Form 8868): Deadline for filing Form 990 or 990 EZ for tax-exempt trusts associated with health and welfare plans.

• June 30: Deadline for processing corrective distributions for failed ADP/ACP test from a 401k plan with eligible automatic contribution arrangement without 10 percent excise tax.

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 call Donald S. Kohla at 678.336.7140 or Jan G. Marsh at 678.336.7135.

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