Flexible Discretionary Match notice requirement

How are other TPA firms handling this new notice requirement? Will your firm be taking responsibility for filling out the notice and sending it to all your clients who have this flexible discretionary matching feature in their Cycle 3 document? When would you distribute the notice- at the beginning of each plan year to all the affected clients?

Thank you.

First, I need to say that I am still working on what this means, so this comment is very "preliminary".  My understanding is that is your discretionary Match is not being allocated as a simple uniform percentage or dollar formula, you must have written documentation defining the formula used and classes getting what formula.  My understanding also holds that within 60 days of making the last deposit of the match for a given year, a written notice must be provided to participants.  If that is correct, your notice would be after the plan year end, assuming that a portion, if not all, of the match is deposits at year end or post year end.