401klubkid

Ok. If PPA restatement is 'substantial' how soon does the plan sponsor need to provide the updated SPD?

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!

Right. My question is around whether there is actually a DOL/IRS requirement that it be allocated annually, or if it is just a best practice. Really wondering if a client that hasn't done this for a couple years would have to go through EPCRS or some other correction method, or if they could just allocate the excess expense account amount to active participants as of the prior year end and call it good.

The account is established for excess revenue from the plan to be deposited into, for the plan to use to pay expenses. Usually plan administration expenses, auditor fees, FA compensation, is paid out of this account. They are also known as ERISA recapture accounts, revenue-sharing accounts, ERISA expense accounts, and plan revenue accounts.

I am having trouble finding an actual regulation or part of the DOL/IRC that references exactly how often ERISA expense account excesses should be allocated to participants. Can anyone help me with this? Is there an actual law/regulation, or is it just a good practice? Everything I have found is related to forfeitures, but does not reference ERISA accounts.