April 2017 HR Alert | Second Quarter Compliance Calendar for Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with various reporting and notice deadlines for their retirement and health and welfare plans. To avoid costly penalties and excise taxes, employers must remain up-to-date with respect to benefit plan reporting and notice deadlines. The calendar below provides second quarter (April – June) key reporting and notice deadlines for calendar year benefit plans (the deadlines are different for a benefit plan with a non-calendar year plan year). Please note that this calendar does not include all applicable reporting and notice deadlines, just some of the common ones.

Deadline Document/Item Description Plans Affected
March 31 (Usual deadline of April 1 falls on a weekend) Notification of Age 70 ½ Required Minimum Distribution (RMD) Deadline for plan to distribute prior year’s required minimum distribution for any terminated employee who reached age 70 ½ or older during the prior year. Qualified Retirement Plans
Deadline for plan to distribute prior year’s required minimum distribution for any active employee who is also a 5% owner and who reached age 70 ½ during the prior plan year.
April 14 (Usual deadline of April 15 falls on a weekend) Deadline for Defined Benefit Plan Contributions First quarter defined benefit plan contributions must be paid (if applicable). Defined Benefit Plans
April 14 (Usual deadline of April 15 falls on a weekend) Excess Deferrals Deadline for plan to distribute prior year’s deferrals in excess of Internal Revenue Code §402(g) annual dollar limit and related earnings. 401(k) Plans
April 17 Underfunded Defined Benefit Plan Notice Deadline for underfunded defined benefit plans to provide notice to the Pension Benefit Guaranty Corporation (PBGC). Defined Benefit Plans
April 28 (Usual deadline of April 30 falls on a weekend) Annual Funding Notice Deadline for the plan administrator to provide a plan funding notice to the Pension Benefit Guaranty Corporation (PBGC) and to each plan participant and beneficiary under the plan. The notice must include, among other information, the Funding Target Attainment Percentage (FTAP) for the current and two preceding plan years. Defined Benefit Plans
May 15 (within
4 1/2 months after the end of the plan year)
Form 990 and 990-EZ Deadline for plan administrator to file Form 990 with the IRS. Form 990 is required for organizations exempt from income tax under Internal Revenue Code Section 501(a) with (i) gross receipts greater than or equal to $200,000, or (ii) total assets greater than or equal to $500,0000 at the end of the tax year.

Employers should file Form 990-EZ for tax exempt organizations with (i) gross receipts of less than $200,000, or (ii) total assets of less than $500,000 at the end of the tax year.

Employers may use Form 8868 to request a 90-day extension.

Health and Welfare Plans
June 30 (last day of 6th month following the plan year) Excess Contributions Deadline for employer to distribute eligible automatic contribution arrangement (EACA) excess contributions and earnings from the prior year.

Please note that for purposes of this calendar, “Qualified Retirement Plans” means all defined benefit and defined contribution plans that are intended to satisfy Code Section 401(a) and “Retirement Plans” means all employee pension plans defined in ERISA 3(2).

Hall Benefits Law recommends that you consult with ERISA legal counsel to assist you with any questions you may have regarding compliance with the first quarter reporting and notice obligations listed above and any other reporting and notice requirements (i.e., COBRA and HIPAA) for your employee benefit plans.

This content is intended to be informational and does not constitute legal advice regarding any specific situation. This material may also be considered attorney advertising under rules of certain jurisdictions.

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