Retirement Deadlines Checklist for October 2022
The executive benefits team at OneDigital is pleased to share the following report on retirement deadlines, prepared by the Employee Benefits group at Isler Dare PC.
As we enter October, here are a few retirement deadlines to keep in mind.
Deadline October 14, 2022
- Distribute Notice of Medicare Part D creditable prescription drug coverage to health plan participants (unless notice has been provided in open enrollment materials)
Deadline October 15, 2022
- Fund Q3 2022 contributions to defined benefit pension plans
- Adopt retroactive amendment to correct 410(b) minimum coverage or 401(a)(4) non-discrimination testing failures for 2021
- File Form 8928 to report excise taxes for noncompliance with obligation to make comparable HSA contributions (assuming Form 7004 was filed to extend due date)
- File Forms 5500 and 8955-SSA for retirement plans, and Form 5500s for health and welfare plans with more than 100 participants (assuming Form 5558 was filed to extend due date for Form 5500)
- File PBGC[i] Form 1 and make payment for annual premium payment, single employer plan variable rate portion of premium, and flat-rate premiums due to PBGC
- Distribute annual benefit statements to participants in non-participant-directed account retirement plans (e.g., ESOP[ii]s) (assuming Form 5558 was filed to extend due date for Form 5500), including lifetime income illustrations
- Distribute Annual Funding Notice for defined benefit pension plans with less than 100 participants (assuming Form 5558 was filed to extend due date for Form 5500)
- Provide notice to terminated vested employees reported on Form 8955-SSA, describing the amount of their vested benefits (assuming Form 5558 was filed to extend due date for Form 5500)
- Utilize contributions correcting 2021 ADP[iii]/ACP[iv] test failures to count as 2021 annual additions
- File Form 5310-A with IRS to give notice of the establishment of a qualified separate line of business (or to revoke a prior year election)
Deadline October 31, 2022
- Provide notice of benefit restrictions under IRC Section 436 to participants if AFTAP[v] for a defined benefit pension plan (certified by actuary no later than October 1) is less than 60% and notice has not previously been provided
- Work with 401(k)/403(b) plan recordkeepers to prepare notices, including QDIA[vi] notice, safe harbor notice, and auto enrollment notice, as required (to be distributed by December 1)
- Have ESOP trustees meet to review and accept annual valuation report for 2021
- Finalize and distribute open enrollment communications and Summaries of Benefits and Coverage (“SBC”)
[i] Pension Benefit Guaranty Corporation
[ii] Employee stock ownership plan
[iii] Actual Deferral Percentage
[iv] Actual Contribution Percentage
[v] Adjusted funding target attainment percentage
[vi] Qualified Default Investment Alternative
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