"Plans may go live with the new safe harbor immediately, even though it is technically not effective until July 20.... [1] Evaluate the current communications strategy and the needs of the workforce, especially in the current COVID-19 environment. [2] Determine what strategy is in the best interest of the plan and its participants taking into consideration effectiveness, ease of use and cost to the plan. [3] Consult your recordkeeping partner or thirdparty administrator to determine their ability to implement the new safe harbor and formulate a timeline that includes each of the safe harbor requirements. [5] Pay special attention to how electronic addresses will be captured and how the new safe harbor system requirements will be carried out."

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