Upcoming compliance deadlines:

12/1     Deadline for 401(k) and (m) safe harbor notices, annual qualified default investment alternative (QDIA) notice, and qualified automatic contribution arrangement (QACA) notice (can be made up to 90 days before the start of the plan year)

12/15    Extended deadline to distribute the Summary Annual Report for plans that filed Form 5500 by October 15 (calendar year plans)

12/31    Deadline for making required minimum distributions for 2020*

12/31   Deadline for making corrective distributions for failed 2019 actual deferral percentage (ADP) and actual contribution percentage (ACP) tests with a 10% excise tax penalty, as well as for making a qualified nonelective contribution (QNEC)

12/31   Deadline for making a prospective amendment to add or remove safe harbor status for the 2021 plan year

12/31   Deadline for making a prospective amendment to add eligible automatic contribution arrangement (EACA) and QACA for the 2021 plan year (must give participants notice at least 30 days prior to the effective date)

2/1   2020 Forms 1099-NEC are due to participants

* If a participant chose to suspend or not receive their 2020 required distribution due to the CARES Act provisions, no RMD is required for 2020.

As always, we hope you enjoy this edition of our newsletter and we look forward to receiving your feedback. Should you have any questions regarding the information contained in the attached materials or our Employee Benefit Plan Services, please feel free to contact me directly.

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About the Author: Michael Giess

Michael is a Partner in the Audit and Business Advisory Services Group, joining Insero from PricewaterhouseCoopers. He has significant experience servicing private and public companies in the manufacturing, service, retail, and wholesale/distribution sectors. Michael also served as Director of Internal Audit for an upstate New York company where he was responsible for establishing an internal audit function and developing the overall audit plan.

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