Safe harbor notices and hardship changes

[JPIngold]

I'm a Relius document user and am seeking advice (since they don't seem to respond as quickly as they used to). They posted a notice on the site with regard to the safe harbor notices saying to select 166b on the checklist and then:

"Clients can run a provisional report within RD ASP using the logic string in paragraph 166b as their selections. This report will assist in determining what action, if any, is needed regarding 166b for 2020 annual notices".

Can anyone out there tell me how to run a provisional report in RD ASP???

If not, does anyone out there have suggestions on the safe harbor notice revisions due to the hardship distribution changes that have not been incorporated in the SPD (or even an SMM) at this point? Some folks hemmed and hawed at ASSPA Annual, but I didn't get anything concrete in the sessions I attended.

Thanks.

James

 

[JPIngold]

I'm going to toss out an answer to my own question and see if anyone has any comments.

I believe that if I simply change both references to 'seeing the SPD for more details' in the section regarding distribution provisions to 'seeing the Administrator for more details', then there is nothing misleading and nothing else in the safe harbor notice that would be affected by the changes to the hardship distribution provisions.

The Administrator would then be able to provide details to the participant upon request.

 

[RatherBeGolfing]

I don't think your solution works.  It is fine to reference a notice or document you have already distributed.  I do not think the safe harbor notice can include, by reference, something the participants do not already have access to. 

[Michelle Mianecki]

In answer to your question on the provisional report, I believe you have to subscribe to FIS's added reporting module service to access this.