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Posted

Is anyone mentioning email delivery of notices in the letter to the employer with the 404a notices?

If yes, what are you saying about it?

I am thinking of a paragraph that goes something like this.

Email may be used to deliver a copy of this disclosure to anyone who uses a computer as a normal part of their job everyday. Paper copies of this disclosure should be distributed to everyone else as soon as convenient but no later than August 30th.

(By the way, is August 30th the right date? Right now I am not sure of anything!)

Posted
Is anyone mentioning email delivery of notices in the letter to the employer with the 404a notices?

If yes, what are you saying about it?

I am thinking of a paragraph that goes something like this.

Email may be used to deliver a copy of this disclosure to anyone who uses a computer as a normal part of their job everyday. Paper copies of this disclosure should be distributed to everyone else as soon as convenient but no later than August 30th.

(By the way, is August 30th the right date? Right now I am not sure of anything!)

We are giving our clients instructing on e-delivery. I do believe that the safe harbor e-delivery method is a two step process. First email informs employee that the second email containing the disclosure is coming if they do not want to receive by email, they must affirmatively request a paper copy. Or something along those lines.

And yes, the date is August 30th.

Posted

Yes, we're including something like what you suggested...actually lifted the language from the regs:

Electronic copies may be sent to participants who use computers as an integral part of their employment duties or to participants who give consent to receive this disclosure electronically. For those participants who do not use computers as an integral part of their employment duties, the disclosure must be distributed via hard copy.

I think the two-step process mentioned by Kathy is for those who don't "use computers as an integral part of their employment duties". If not, well, tough nuts.

Yes, Aug 30 is the date.

Ed Snyder

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