QPSA Written Explanations

[Guest StargazerL81]

May the written explanation of a QPSA be included in the SPD or must it be a separate written explanation?

MBL

[Guest HarveyC]

I have had some clients indicate that they comply with the QPSA/QJSA notice requirements via posting in SPD but I have advised that this is not a sufficient delivery method.

§1.417(a)(3)-1(a)(3) says...

Required method for providing section 417(a)(3) explanation. A section 417(a)(3) explanation must be a written explanation. First class mail to the last known address of the participant is an acceptable delivery method for a section 417(a)(3) explanation. Likewise, hand delivery is acceptable. However, the posting of the explanation is not considered provision of the section 417(a)(3) explanation.