Participant Statements

[Nassau]

What are the implications if a Recordkeeper does not display the vesting/vested balance, or a disclosure that they are unable to provide an accurate vested balance on the quarterly participant statements?

[Bird]

I think it is a qualification requirement. But note that instead, you can provide information to enable them to determinate their own vesting.

PPA Section 508

© ALTERNATIVE NOTICE.—The requirements of

subparagraph (A)(i)(II) are met if, at least annually and in

accordance with requirements of the Secretary, the plan—

‘‘(i) updates the information described in such paragraph

which is provided in the pension benefit statement, or

‘‘(ii) provides in a separate statement such information as is

necessary to enable a participant or beneficiary to

determine their nonforfeitable vested benefits.