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SPD Mailing


401klubkid

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Quick question on SPD fulfillment to plan participants. I've had trouble finding specifics on timing of when these need to be provided to existing participants. I have seen the 'every 5 years' timeframe, as well as after a substantial plan modification. My question is, what is substantial? I have a plan that restated their document for PPA recently. Nothing major was updated in the plan when it was restated, so is a new SPD mailing required? The SPD is currently available via the TPA's website when participants access their individual accounts. 

Thanks!

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We tend to "over" distribute.  "Substantial" is a judgement call, and we look at it as "how long would the SMM be" as well as how many SMMs have been issued since the last SPD, and then if we think it or cumulatively "them" have a substantial impact, re-issue the SPD.  For us, it's an "automated" process (and we actually don't distribute - but provide it to the plan sponsor to do so).

For PPA - even though the plan "specifics" weren't substantially changed, enough was changed to require a restatement, so I think it requires a new SPD.

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I would presume 210 days after the year the PPA restatement was effective for.  In fact, I'm eagerly awaiting my former TPA employer to send me an SPD for the first time since 2000.

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