Self Directed Brokerage / FBO Accounts / Lifetime Income Disclosures

There is a rumor going around that those disclosures are due by 6/30/2022.  Is that correct, and how is that even possible?  Some of those plans we don;t get census data in a timely manner, etc. so may not be in a position to issue statements until say October 14th.

Thoughts?

Another BenefitsLink discussion raises the same worry.

In that discussion, I hinted that some practitioners might consider it enough that an illustration generated from a participant’s June 30, 2022 balance is delivered before September 18, 2022.

For the background and explanation, see https://benefitslink.com/boards/index.php?/topic/69012-lifetime-income-illustrations/.

HA!  I was about to add to a link to that thread!