Q4 Plan Sponsor Checklist
2022 IRS Form 5500 & IRS Form 8955-SSA Extension Deadline: Plan sponsors who were granted an extension to file the 2023 IRS Form 5500 & IRS Form 8955-SSA by filing a Form 5558 are now required to submit the final 2021 Form 5500 & Form 8955-SSA by October 15, 2023 (including auditor's report for large plans). Typically a plan covering more than 100 participants at the beginning of the plan year is considered a large plan and will require a plan audit. However, if the plan meets the conditions of the 80 to 120 Participant Rule, it may file as a small plan. Under this rule, if the number of participants covered under the plan as of the beginning of the plan year is between 80 and 120, and a small plan annual report was filed for the prior year, the plan administrator may elect to file as a small plan.
Annual Notices: Plan sponsors that have adopted plans with automatic enrollment or safe harbor provisions should contact their service provider to ensure annual notices are distributed 30-90 days prior to the beginning of the plan year. In addition, the participant notices noted below must be distributed by the following deadline dates:
Summary Annual Report (SAR) - The SAR for 2022 must be distributed to all participants by September 30, 2023 unless an extension was granted to file the 2022 Form 5500. If an extension was granted, the 2022 SAR will need to be distributed to all participants by December 15, 2023.
Annual 404(a)(5) Participant-Level Fee Disclosure - This disclosure is required to be distributed no later than 14 months from the last time it was distributed to participants (In 2014, the DOL granted a 2 month grace period after the 12 month required timeframe for distributing these disclosures).
Qualified Default Investment Alternative Notice (QDIA) - Plans containing a default fund that qualifies as a QDIA, are required to provide an annual notice 30-90 days prior to the beginning of the plan year in order for the default fund to be recognized as a QDIA by the DOL. The DOL will provide additional liability protection to plan sponsors as it relates to the plan default fund if it is designated as a QDIA.
403(b) Universal Availability Notice: An annual notice is required to be provided to all employees in 403(b) plans, except for Church plans.
Flexible Discretionary Matching Contribution Notice: Plans that provide a Flexible Discretionary Matching Contribution are required to provide a notice to participants no later than 60 days after the final discretionary matching contribution is provided for the plan year.
2023 Discretionary Amendments: Amendments for plan design changes that became effective in 2023 need to be formally adopted by December 31, 2023. Plan sponsors should ensure they maintain executed copies of all plan amendments and restatements.
Mandatory Cash-outs, Forfeiture Accounts & ERISA Budgets: Plan sponsors should work with their providers to coordinate mandatory cash outs of small plan balances prior to year end. In addition, plan sponsors should review balances for their forfeiture account and ERISA Budget with their provider and USI Consultant to ensure they are utilized appropriately.
Q4 Plan Sponsor Literature & Education
Retirement Plan Spotlight Newsletter: Periodic newsletter and legislative updates designed to highlight various employee benefit matters relating to Defined Contribution and Defined Benefit plans. >Click here
Market and Legal Updates: >Click here
Plan Sponsor Literature: Fiduciary Fundamentals for ERISA Plan Sponsors - This literature piece goes over the four basic fiduciary duties under ERISA that plan sponsors should adhere to. >Click here
404(c) Compliance: This communication provides information pertaining to 404(c) guidance for plan sponsors >Click here
Q4 Employee Communications
Understanding Tax Benefits: This education piece helps employees understand the importance of saving in their retirement plan to take advantage of tax deferred compounding. >Click here
Reach/November Budget: Budgeting tips to consider when planning for holiday shopping. >Click here
Reach/December Budget: Checklist to aid employees in meeting retirement and financial goals in the New Year. >Click here
In addition to the employee communications noted above, please feel free to check out our Learning Station Website to access additional employee education materials and webinar announcements.