austin3515 Posted December 16, 2018 Posted December 16, 2018 Assuming the top-hat exemption was filed with DOL when the plan was established, is there a requirement to notify them of a termination? Any sites on this would be tremendously appreciated... Austin Powers, CPA, QPA, ERPA
EBECatty Posted December 17, 2018 Posted December 17, 2018 Not a cite affirmatively saying "no filing is required" but 29 CFR 2520.104-23 says a top-hat plan "shall be deemed to satisfy the reporting and disclosure provisions of part 1 of title I [of ERISA]" if the plan sponsor files the required top-hat letter with DOL and provides plan documents to DOL upon request.
Bob the Swimmer Posted December 17, 2018 Posted December 17, 2018 no requirements I am aware of---remember that DOL's online registration filing only began a couple of years ago--I had several of the first 20 filings with them. Before that, my sources told me they were housed in a warehouse someplace and not really reviewed.
austin3515 Posted December 18, 2018 Author Posted December 18, 2018 Whoa... on line filing process? Can you tell me more? I’m still mailing paper... Austin Powers, CPA, QPA, ERPA
Bob the Swimmer Posted December 18, 2018 Posted December 18, 2018 Sure--it's on the DOL website and they send you a confirmation of the receipt of your exemption certificate--the exact same requirements for the paper filing.
XTitan Posted December 18, 2018 Posted December 18, 2018 20 hours ago, austin3515 said: Whoa... on line filing process? Can you tell me more? I’m still mailing paper... https://www.dol.gov/agencies/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/e-file/tophat-plan-filing-instructions "Enjoy" - There are two types of people in the world: those who can extrapolate from incomplete data sets...
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