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Posted

I just wanted to vent for a moment here...has anyone else thought about the fact that these safe harbor notices are supposed to be written as such that they can be understood by the "average participant", and yet for many of my plans, we are supposed to add all of this info that I know will only confuse the already confused masses?!?!

As an example, I have a safe harbor multiple employer plan. The plan currently has basically only 401(k) deferrals and safe harbor matching. The plan doc was written to allow for discretionary match and/or profit share, but the chances are slim to none that any of the Employers will ever take advantage of those provisions.

We had a great (one page!) safe harbor notice for 2006, that explained many of the things required in the new notice, but did use the SPD reference for things like the "other employer contributions" and "vesting" that now are required in the notice.

What is the purpose of the SPD if we have to regurgatate all of that info over again for other employer contributions that are not even related in any way to the safe harbor match???

Can anyone make sense of this for me.......?

Guest Pensions in Paradise
Posted

You are still allowed to cross-reference the SPD regarding other contributions under the plan. So it is still possible to have a one-page safe harbor notice.

Posted

We tried to make ours as short as possible, but with the vesting disclosures, it's tough to get it on one page. Ours ranges from 1 1/2 to 2 full pages depending on how complicated the plan is.

Austin Powers, CPA, QPA, ERPA

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