Participant Statements

[Nassau]

This is a general question. PPA states that in a plan where the participant has the right to direct the investment of the assets of their account that once each calendar quarter a statement must be furnished. Is it a regulatory requirement to include participants' vested balance on quarterly statements? If a client can only confirm vesting on an annual basis and the vested balance is only displayed on the 4th quarter statement, is this in compliance with the regulatory requirement?

[Bird]

My recollection (and notes, which I trust more than my recollection...) say that it is ok to do it (vesting on statements) once per year. If a plan we handle is not on a platform that provides the necessary language, we were (are) generally going with a supplemental statement each quarter to cover the permitted disparity and/or investing principles language, and then once per year doing our own statement that includes vesting. In a handful of rare cases we're not generating our own comprehensive statements and are just generated a supplemental statement for vesting - basically spitting out the SPD language about how to calculate their vested percentage.