PPA Quarterly Benefit Statement Requirement

[MarZDoates]

If we have a plan year that runs from November 1, 2006 through October 31, 2007, by when is the first quarterly participant statement due? 45 days after 1/31/07? Thanks for any and all input.

[JanetM]

PPA stays quarterly stmts are required for plan years beginning 1/01/07. So I read it as not being required of your plan until 2008. If it were me, I would do it as soon as I could, why wait.

[PLAN MAN]

How does it work for plans that do not start/end on a calendar quarter such as this plan? Would the first statement be required for the calendar quarter ending December 31, 2007?

Field Assistance Bulletin No. 2006-03

"With regard to individual account plans that permit participants and beneficiaries to direct the investment of assets in their account, section 105(a)(1)(A)(i) requires that a pension benefit statement be furnished at least once each calendar quarter.

If a plan operated on a fiscal year basis, with the first plan year (after December 31, 2006) beginning on July 1, 2007, the first pension benefit statement required to comply with the new requirements would be required to be furnished for the quarter ending September 30, 2007."

[MarZDoates]

So I guess that since the first day of my fiscal plan year (after December 31, 2006) is November 1, 2007, then the first quarterly statement would be due 45 days after 1/31/08. Does that sound correct?

As always, thanks again for all your input. It is greatly appreciated!

[PLAN MAN]

I don't think that is correct. Section 508 of the PPA says that a plan shall furnish a benefit statement at least one each calendar quarter to a participant or beneficiary who has the right to direct the investment of assets in his or her account under the plan.

I think that provision means you must provide a benefit statement for the calendar quarter ending December 31, 2007. What do others think?