"Another BenefitsLink discussion includes some observations about how much or how little help the new Default Electronic Disclosure rule offers if an employer/administrator lacks email addresses for the portion of participants who are severed from employment. A 2002 rule allows electronic delivery if, with other conditions, the employee/participant can access the communications using an email system the employee uses as 'an integral part' of the employee's work for the employer. Under last week's new rule, there is no such 'integral part' condition and an employer-provided electronic address can be enough to invoke the new regime if the employer assigns the address for some employment-related purpose beyond the retirement plan's communications. A retirement plan's administrator may continue to rely on such an address (if there is no bounce-back or other operability defect) after a participant's severance from employment.

If an employer/administrator seeks to grow the population of (future) former employees who can remain in the new electronic regime, should an employer assign an email address for every employee? (Imagine an employer tells its employees that human-resources and safety announcements will be sent to employees' employer-provided email addresses.)"

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"I'm a sole proprietor that has a Prototype Profit Sharing Plan that was abandoned by a national provider. Can someone recommend a provider that offers Prototype plan documents?"

"Participant has vested balance of $90,000. Takes out a loan for $35,000. We display their account balance now as $55,000 and a loan balance of $35,000. Six months later, Participants wants to take a second loan. The second loan calculation would be based on the $90,000 ($55,000 account balance plus the $35,000 loan balance) and not just the $55,000 account balance, right?"

"Plan Sponsor maintains a Safe Harbor 401(k) Plan with Basic Safe Harbor Match. Safe Harbor match is calculated annually per plan document. Plan Sponsor would like to calculate safe harbor match for the period covered under the PPP Loan which they received. Should this safe harbor match be calculated for the PPP period and can it be allocated to the participant's directed account at their asset custodian?"

"Other than the risk of bankruptcy or other loss, is there any problem with an employer sponsoring a HRA for eligible retirees with notional accounts tracking reimbursement from current operating funds?"