Are you a benefit plan fiduciary, or maybe you are the administrator for a benefit plan and work closely with the plan fiduciary? If you are, then hopefully this article will provide some key dates and tasks to remember; or, if you are currently aware of all these dates and tasks, then hopefully this article provides some peace of mind that you are meeting your fiduciary responsibilities. (However – please note – this article is not meant to cover/explain all key dates and fiduciary responsibilities).
1) Have you scheduled your 2013 plan year performance review? (Assuming your plan year end is 12/31/2013). Be sure to invite your third party administrators to attend, and maybe even your plan auditors. You should also review your plan’s investments and ensure they are still practical and supportive of your plan’s investment policies and strategies.
2) Be sure to re-evaluate all goals and objectives that you established at the beginning of the year. (I.e. increase employee deferral participation rates, provide more educational workshops, and track your employees’ usage of the third party administrator’s website resources).
3) Review any plan amendments that were signed in the prior plan year and evaluate the results to the expected outcomes. Also, start planning and considering new regulations that may require 2014 amendments.
4) Did your employer acquire another company, or maybe your employer was acquired. Did you consider the necessary plan amendments and documents needed?
5) Have you been with the same third party service provider for more than a few years? Are you still comfortable that they are providing the required level of service at the most affordable and/or acceptable fee rates?
6) Be sure to review all the reports that were provided by your third party administrator for reasonableness and accuracy. (Trust statements, administrative expenses, loan reports, distribution and contribution reports, etc.)
7) Did you address the auditor comments from the prior year audit?
Key Dates (most are assuming a December 31, 2013 year-end) *(reference communications.fidelity.com)
1) January 31, 2014 is the deadline for mailing IRS Forms 1099-R to those participants that had distributions made in the prior plan year.
2) February 28, 2014 is the deadline for filing the IRS Forms 1099-R with the IRS.
3) March 15, 2014 is the deadline for issuing distributions to those participants who failed the compliance ADP/ACP tests (if applicable).
4) March 31, 2014 is the deadline for reporting excise taxes for the late return of excess distributions using IRS Form 5330.
5) April 15, 2014 is the deadline for corrective distributions of excess deferrals.
6) July 31, 2014 is the deadline for filing Form 5558 with the IRS to request a 2.5 month extension in the filing of Form 5500/8955-SSA, and independent auditors report (if large plan filer).
7) July 31, 2014 is the deadline for filing Form 5500/8955-SSA and independent auditors report (if large plan filer), if not extending filing.
8) September 30, 2014 is the deadline for distributing the Summary Annual Report (often called SAR) to plan participants, assuming a 2.5 month extension was not requested from the IRS.
9) October 15, 2014 is the deadline to file Form 5500/8955-SSA with the Department of Labor for plans that filed the extension 5558 (see #6 directly above).
10) December 15, 2014 is the deadline for distributing the Summary Annual Report assuming the 2.5 month extension was filed (see #8 directly above).
If you have any questions on the key tasks or key dates noted above, feel free to contact us.
Victor L. Fuentes