nicole_m

In regard to the last comment about RK systems, just wanted to note that some systems do automatically offset when a distribution occurs, but only if the withdrawal was triggered by was due to a termination of employment triggering event (though I'm sure there are other systems that do indiscriminately offset with any type of distribution, due to unsophisticated programming.)

And that was the intent - we're just wondering whether there would still be concerns from a technical perspective even with a cover letter that included that type of language. For example, does the "no more than 90 days" guideline present any concerns for a plan that has a 1 year eligibility requirement, and the notice goes to someone who will not meet eligibility for some time yet?

What are your thoughts on providing the following annual participant notices to the entire employee population (everyone in the employer's census) regardless of whether they are yet eligible to participate in the plan? -QDIA -Safe Harbor -Automatic Enrollment (ACA/EACA/QACA) My thought is that there might be some legal risk for the employer (in that it could be providing misleading information to someone who is not yet eligible) and it could also be confusing for the employee who has no idea whether the notice even applies to them. Beyond these concerns, are there technical issues as well?