MaryJ Posted July 16, 2024 Posted July 16, 2024 Our company has made a plan restatement of our Top Hat Plan. After this restatement, do we need to file a statement of this change with the DOL? i.e. using this online filing tool? https://www.askebsa.dol.gov/tophatplansearch
CuseFan Posted July 17, 2024 Posted July 17, 2024 No, you only need to register a plan once. New plans of the same employer require registration but not amendments/restatements of existing plans. At least that is my understanding. Luke Bailey 1 Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
HCE Posted July 18, 2024 Posted July 18, 2024 I agree with CuseFan that no re-registration is needed. There is some debate over whether a new arrangement requires registration, with some saying it is not required. I've always taken the position that best practice is to register new plans because the registration is so easy and it's not worth the downside of failing to register in the event it is determined that it should have been done. Luke Bailey 1
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