SECURE ACT Safe Harbor Notice

We know that the 3% Safe Harbor Annual Notice has been eliminated with the SECURE Act. However we received information from VOYA (attached - page 3) that says it is still required to give participants a notice if they are a new hire. I haven't read this anywhere else in regards to the SECURE Act. I would assume that only the SPD would need to be distributed?

0310_001.pdf

This is our understanding as well. Also, if there is a discretionary match that is intended to automatically satisfy the ACP test, then an annual notice is still required. We have essentially been providing a single SH/QDIA/ETC notice, so I don't think this is really worth fooling with. But it does help if someone forgets to distribute a notice.

Hi Bill,

Please clarify if it is your understanding that an initial notice is still required even though an annual notice is not required or if it is your understanding that only the SPD is required, and not an initial notice. Thank you.