TPApril Posted October 10, 2019 Posted October 10, 2019 Is there a guideline regarding how often participants in a non-safe harbor 401(k) plan need to be informed that there is the option to invest in a brokerage account? In this situation, participants are either in the Pooled account, or can pull out vested balances to put into brokerage account. They receive annual statements of their balances and vested amount. Information about the investment options is provided in the SPD.
C. B. Zeller Posted October 10, 2019 Posted October 10, 2019 What about the quarterly notice informing participants of their right to direct investments? edit: We call it the "PPA Notice" around our office but I feel like that name is pretty outdated at this point. What does everyone else call it? "ERISA 105(a)(1)(A)(i) Notice" doesn't have the same ring to it. ugueth 1 Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance. Corey B. Zeller, MSEA, CPC, QPA, QKA Preferred Pension Planning Corp.corey@pppc.co
TPApril Posted October 10, 2019 Author Posted October 10, 2019 The pooled account is valued annually, so annual statements are sent out, rather than the PPA Notice.
C. B. Zeller Posted October 10, 2019 Posted October 10, 2019 If they have the right to direct investments, then I think they should be receiving quarterly notices. ugueth 1 Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance. Corey B. Zeller, MSEA, CPC, QPA, QKA Preferred Pension Planning Corp.corey@pppc.co
Larry Starr Posted October 10, 2019 Posted October 10, 2019 1 hour ago, C. B. Zeller said: If they have the right to direct investments, then I think they should be receiving quarterly notices. I have the same concern; why do you think you DON'T need the quarterly notices? I think you might have uncovered a bigger problem. Larry Lawrence C. Starr, FLMI, CLU, CEBS, CPC, ChFC, EA, ATA, QPFC President Qualified Plan Consultants, Inc. 46 Daggett Drive West Springfield, MA 01089 413-736-2066 larrystarr@qpc-inc.com
TPApril Posted October 11, 2019 Author Posted October 11, 2019 So actually, because there is the option of directing one's account balance in a brokerage account, the pooled account, which appears to be historically valued annually, should be valued quarterly.
Larry Starr Posted October 11, 2019 Posted October 11, 2019 17 hours ago, TPApril said: So actually, because there is the option of directing one's account balance in a brokerage account, the pooled account, which appears to be historically valued annually, should be valued quarterly. Is there a question there? Lawrence C. Starr, FLMI, CLU, CEBS, CPC, ChFC, EA, ATA, QPFC President Qualified Plan Consultants, Inc. 46 Daggett Drive West Springfield, MA 01089 413-736-2066 larrystarr@qpc-inc.com
Pam Shoup Posted October 11, 2019 Posted October 11, 2019 I would also believe that an annual 404a-5 notice would be proper in this case disclosing the fees for the brokerage window and the other parts of the 404a-5 notice requirements when you have participant direction of at least part of the plan assets. Pamela L. Shoup CEBS, RPA, QKA
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