A Note from BDO's ERISA Practice Leaders
With the rush of plan audits and Form 5500 filings winding down, join us for this edition of our Q3 ERISA Roundup. As September marks the 50th anniversary of ERISA, this edition explores the history of employee benefits plans and how protections have grown in the last 50 years. Also included is a link to our latest podcast discussing implementation of SECURE Act provisions for long-term part-time employees.
Our dedicated ERISA practice leadership team is excited to welcome Michael Belonio to the Assurance Principal Group. His expertise and leadership in employee benefit plan matters will undoubtedly enhance our practice as we continue to provide valuable insights and guidance.
Staying current on ERISA topics is simplified with BDO: Follow along with our regular insights at our BDO ERISA Center of Excellence and our podcast series BDO Talks ERISA. We welcome your feedback on our content by emailing us.
ERISA Center of Excellence
BDO’s ERISA Center of Excellence is your source for insights on emerging regulations, industry trends, current topics, and more. Visit us at www.bdo.com/erisa or follow along on Twitter: @BDO_USA and #BDOERISA.
In This Issue
- BDO talks ERISA Podcast – Navigating New Long Term Part Time Employee Provisions Under the Secure Act
- Understanding the Impact of Workforce Reductions on 401(k) Plans
- The Growth and Impact of Employee Protections in the Last 50 Years
- Milestones in Employee Protections: Reflecting on ERISA’s Legacy
- 2024 Audit Innovation Survey
2024 Deadlines and Important Dates
Sponsors of defined benefit and defined contribution retirement plans should keep the following deadlines and other important dates in mind as they work toward ensuring compliance for their plans in 2024. Dates assume a calendar year plan. Some deadlines may not apply, or dates may shift based on the plan sponsor’s fiscal year. For additional support, please contact your BDO representative.
October
- 3 / Action: Distribute annual notices to participants no earlier than October 3 and no later than Dec 2, including notices for: 401(k) Plan Safe Harbor Match, Automatic Contribution Arrangement Safe Harbor, Automatic Enrollment and Qualified Default Investment Alternatives (QDIA).
- 15 / Fund: October 15 possible third quarter 2024 contribution due for defined benefit pension plans.
- 15 / Action: October 15 is the extended deadline for filing IRS Form 5500 and IRS Form 8955-SSA.
- 15 / Action: October 15 is the extended deadline for filing individual and C-Corp tax returns.
- 15 / Action: If an extension was filed, October 15 is the deadline to fund defined contribution employer contributions for C-Corporations and Sole Proprietors.
- 15 / Action: October 15 to open a Simplified Employee Pension (SEP) plan for extended tax filers.
- 15 / Action: Send annual funding notice to participants of single- and multi-employer defined benefit plans with 100 or fewer participants by October 15.
- 15 / Action: October 15, defined benefit plan PBGC Premium filings and payments due.
- 31 / Action: Single-employer defined benefit plans that are less than 60% funded or are 80% funded and have benefit restrictions triggered must inform participants by October 31 or 30 days after the benefit restriction applies.
December
- 2 / Action: Distribute annual participant notices no later than December 2. These include notices for: 401(k) Plan Safe Harbor Match, Automatic Contribution Arrangement Safe Harbor, Automatic Enrollment and Qualified Default Investment Alternatives (QDIA).
- 15 / Action: December 15 is the extended deadline to distribute Summary Annual Report (SAR) when the Form 5500 was filed on October 15.
- 31 / Action: December 31 is the final deadline to process corrective distributions for failed ADP/ACP testing; a 10% excise tax may apply.
- 31 / Action: Ongoing required minimum distributions (RMDs) for 5% business owners and terminated participants must be completed by December 31.
- 31 / Action: Amendments to change traditional 401(k) to safe harbor design, remove safe harbor feature or change certain discretionary modifications must be completed by December 31. Amendments to change to safe harbor nonelective design must be completed by Dec 1 of given plan year for 3% or by Dec 31 of the following year for 4% contribution level.
- 31 / Action: Plan sponsors must amend plan documents by December 31 for any discretionary changes made during the year.
Stay Up to Date with Our Podcast, BDO Talks ERISA
Our ERISA Center of Excellence releases a podcast - BDO Talks ERISA! This series covers best practices around all things ERISA and any other HR-related topics, including:
- How to avoid common compliance issues
- How to navigate the ins-and-outs of ERISA’s fiduciary provisions
- Our own experiences working for BDO’s ERISA Services group
- A deeper dive into the insights we share through our BDO ERISA Center of Excellence
Listen to new episodes of BDO Talks ERISA here or subscribe on Apple Podcast or Spotify. If you have suggestions for future topics or have a question for us to answer, please send us an email.