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Message Boards Digest

July 19, 2021

Here are the most recently added topics on the BenefitsLink Message Boards:

thepensionmaven created a topic in Retirement Plans in General

Looking for Paginated Copy of Rev. Proc. 2021-30

"Does anyone have a copy of Rev. Proc. 2021-30 with page numbers in the Table of Contents?"

2 replies so far   |    Click Here to Add a Reply

melba99 created a topic in 401(k) Plans

Proposed Mid-Year Amendment to Safe Harbor Enhanced Match Allocation

"Our plan currently has a safe-harbor enhanced match allocated each pay period with no true up at the end of the year. We now wish to do a true-up at the end of the year. The plan document provider says to amend the plan now to provide for the match allocation to be at year-end, with pre-funding per payroll period, rather than having the plan provide for a per-pay period allocation, with a true-up at the end of the year. Is there a difference between the two approaches?"

No replies yet   |    Click Here to Add a Reply

5500sorBust created a topic in Form 5500

Unitized Funds on Schedule of Assets Held at End of Year

"If a plan is invested in a unitized fund with multiple underlying mutual funds, does each of those underlying mutual funds need to be split out and reported on the Schedule of Assets Held at End of Year? Or can the total balance be reported as just 1 unitized 'mutual fund' asset?"

No replies yet   |    Click Here to Add a Reply

Peter Gulia created a topic in Communication and Disclosure to Participants

Will a Recordkeeper Deliver Its Customer's 404a-5 Notice?

"An ERISA rule -- 29 C.F.R. Section 2550.404a-5 -- calls an administrator of an individual-account retirement plan that provides participant-directed investment (even if no fiduciary seeks ERISA Section 404(c) relief) to furnish regularly a disclosure document that meets several requirements specified in the rule.

Although the rule's command applies to a plan's administrator, for most plans a recordkeeper or other service provider does the work--not only in delivering the notice but also in assembling the notice's investment-related information and other disclosures.

What happens if a plan's administrator wants the delivery service but not the assembly service?

Imagine that a plan's sponsor/administrator is unwilling to adopt its recordkeeper's standard 404a-5 notice. And using the part the recordkeeper allows its customer to customize won't fix the problem. The customer is willing, at its effort and expense, to write its own 404a-5 notice, retrieve and insert the investment information, and deliver to the recordkeeper by a sharp cut-off date two days after each quarter-close, the print-display file of the 404a-5 notice to be delivered. The page count and other technical points conform to what the recordkeeper does normally. The plan's administrator accepts responsibility for its communication, and the sponsor/administrator exonerates and indemnifies the recordkeeper for relying on the administrator's instruction.

In your experience, does a recordkeeper deliver the customer-prepared notice? Refuse to deliver an outside-prepared 404a-5 notice because doing so would be too much disruption to the recordkeeper's work methods?

Does the response vary with the size of the customer? If so, how big must a plan be to get this delivery service?"

2 replies so far   |    Click Here to Add a Reply

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