204h notices

[Gary]

Based on what I have seen in connection with 204h reduction in future accruals notices, theys/b provided to all plan participants and beneficiaries receiving benefits and alternate payess of a QDRO.

As far as I know such notice does not have to b e provided to a trustee, or employer, or plan administrator, etc.

I'm not sure what employee org (i.e. DOL) should get such notice or where it would be delivered, etc.

I am curious for comments on the above.

BTW, the plan subject to this reduction is a 2 participant plan

Thanks.

[SoCalActuary]

Based on what I have seen in connection with 204h reduction in future accruals notices, theys/b provided to all plan participants and beneficiaries receiving benefits and alternate payess of a QDRO.

As far as I know such notice does not have to b e provided to a trustee, or employer, or plan administrator, etc.

I'm not sure what employee org (i.e. DOL) should get such notice or where it would be delivered, etc.

I am curious for comments on the above.

BTW, the plan subject to this reduction is a 2 participant plan

Thanks.

I am not of the belief that a 204h notice is required for participants who are not affected. Non-employees who are retired or terminated vested are not affected by a reduction in future accruals.

If you have research that indicates a different conclusion, please share it.

[Gary]

I agree with your comments.

I was wondering if trustees, plan administrator, employer, employees needed to receive such a notice?

I'm of the belief that only affected participants should receive it, but though I am not a lawyer, I work at a law firm that is a bit argumentative about stuff. Even the paralegals are a nuisance.

So I told them that other than affected participants those other categories stated above need not receive such notice.

Thus the reason why I presented it here for any other views.

[Andy the Actuary]

Being from Missoura -- The Show-Me State -- I always ask for chapter and verse when an assertion is counter-intuitive. If you ask enough times, they'll quit assertin'

[Guest Sieve]

The Notice also must be provided to unions representing participants impacted by the amendment. (Treas. Reg. Section 54.4980F-1, Q&A-10(a).)

Of course, there may be other, non-204(h) required notices for events connected with the reduction of future accruals that might be required (e.g., reprotable event, notice of intent to terminate, etc.).