k man Posted November 18, 2005 Posted November 18, 2005 Can someone please explain how the final 401(k) regs effect the safe harbor notice? do you need to include information about specific plan provisions?
Guest BobK Posted November 18, 2005 Posted November 18, 2005 The Final K and M regs revised the items that the SH notice can reference in the SPD. In particular, no longer can the vesting and in-service withdrawal provisions reference the SPD. They must be spelled out in the notice.
k man Posted November 21, 2005 Author Posted November 21, 2005 that is one of the most rediculous things the IRS has ever done. for service providers that are responsible for 100's of plans it has become more difficult to notify employees.
Guest jetfaninmn Posted November 21, 2005 Posted November 21, 2005 Is there a site with sample verbage?
Larry M Posted November 21, 2005 Posted November 21, 2005 I believe that was an oversight and IRS, unfortunately, informally, is requesting comments from practitioners to protest this omission.
MarZDoates Posted November 22, 2005 Posted November 22, 2005 For those of us that have already sent out our safe harbor notices, should we send out revised ones or not? So much for trying to be efficient. QPA, QKA
FormsRstillmylife Posted November 22, 2005 Posted November 22, 2005 Good question! The regulations are effective for the 2006 plan year; so, Option 1: They are not effective for the safe harbor notice, because it is still 2005. Option 2: They are effective for the safe harbor notice, because it is being issued for the 2006 plan year.
Guest BobK Posted November 23, 2005 Posted November 23, 2005 IRS reps at the ASPPA Annual Conference were pretty clear that it is option #2. The regulations apply for the 2006 plan year. That would include the notice given now for the 2006 Plan Year
Guest darrensoup Posted November 28, 2005 Posted November 28, 2005 Can someone please explain how the final 401(k) regs effect the safe harbor notice? do you need to include information about specific plan provisions? If you already sent SH notices to clients early, are most of you changing them? The notices we already sent reference the SPD regarding other contributions.
R. Butler Posted November 29, 2005 Posted November 29, 2005 If you already sent SH notices to clients early, are most of you changing them? The notices we already sent reference the SPD regarding other contributions. We are resending. Its a pain, but we'd rather be safe.
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