Required Notices for Unenrolled Participants

[CDA TPA]

Under SECURE 2.0, plan administrators do not have to furnish certain disclosures, notices, or plan documents to unenrolled participants if they provide the unenrolled participant with an annual reminder notice about the participant's eligibility to participate in the plan and any election deadlines.  The unenrolled participant must have received the SPD when initially eligible. 

From what I've read about the unenrolled participant notice, the required content seems to mirror the safe harbor notice.  Would you agree?

With the SECURE 2.0 notice relief, is the 404a5 fee disclosure distributed to only (a) participants with an account balance and (b) newly eligible employees?  Does an unenrolled participant need the 404a5 fee disclosure?

What are your TPA firms doing?  What documents are you telling your clients that they need to distribute by December 1st? 

For a non-safe harbor plan, what needs to be distributed to ongoing participants prior to 1/1 in a non-safe harbor plan?  Just the QDIA (when needed) and fee disclosure?  If the plan doesn't need to give a fee disclosure to an unenrolled participant, does than now create the need to draft a notice to unenrolled participants?

Thank you!