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Will updated SPD satisfy notice requirement for fee change

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A plan being restated for Post-PPA will update fees for individual participant expenses. This restated plan is effective on 1/1/2022. Since the SPD reflects the updated fees, is that sufficient to satisfy notice requirements for fee changes, or is it necessary to issue a notice notifying participants of this change to be effective 30 days after the notice is given?

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If this is for a participant directed plan, you are going to need to update the 404a-5 notice and distribute that notice 30 days prior to the effective date of the change.  You can add a cover letter to the notice that it is being updated for fee changes.

Pamela L. (Bobersky) Shoup CEBS, RPA, QKA

AMI Benefit Plan Administrators, Inc.

100 Terra Bella Drive

Youngstown, Ohio 44505



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