Have You Noticed All of the Participant Notice Requirements?

There are potentially more participant notices that apply to a retirement plan than can be counted on both hands. Not all notices apply to all types of plans and some only apply to certain participants. Some are required quarterly, some annually and some only as needed. It is a big task to manage them all when each one may have a different distribution deadline.

Below are most of the key participant notices that apply to ongoing defined benefit (DB) and defined contribution (DC) plans. IAI provides many of these notices. However, your plan’s attorney or investment company may have their own versions (such as Summary Plan Descriptions or salary deferral agreements). There are other participant notices that may apply to your plan that IAI does not provide (such as fee disclosures).

A basic outline and description of participant notices, including notices not listed here, is available on the IRS’ website.

Type of Notice Applicable to DB, DC or Both? Requirement for New Participants Prior to Entry? Requirement for Which Participants? Frequency of Notice
Summary Plan Description (SPD) Both Yes All As needed¹
Summary of Material Modifications (SMM) Both Yes All As needed²
Beneficiary Designation Form Both Yes All As needed³
Salary Deferral Agreement/ Salary Deferral Election Form DC (with 401(k)) Yes New, Active As needed4
Safe Harbor Notice DC (with Safe Harbor 401(k)) Yes New, Active Annually
Annual Benefit Statement Both All Annually5
Annual Participant Notice DC All Annually
Quarterly Participant Notice DC All Quarterly
Summary Annual Report (SAR) Both6 All Annually
Annual Funding Notice (AFN) DB (if PBGC covered) All Annually
Quarterly Installment (Contribution) Notice DB All Annually (depending on plan’s funded status)
Benefit Restriction Notice DB All Annually (depending on plan’s funded status)
Suspension of Benefits Notice DB Active at Normal Retirement Age Annually
1For a new plan, participants should receive within 120 days after plan is adopted. New participants should receive within 90 days of their plan entry date. All participants should receive when the plan document is restated, or generally every five years.
2If the plan has been amended without an updated SPD, an SMM is generally required. The distribution timing of the SMM for a plan amendment will vary. Any SMMs should be distributed along with the SPD.
3In addition to completing this form prior to plan entry, a participant may (and should) complete a new designation anytime they have a change in marital status and/or wish to change their beneficiary(ies). If a participant has a same-sex marriage, then a previous election may be out of date. Any election made before the first day of the plan year in which the participant attains age 35 will expire at that time.
4In addition to completing this form prior to plan entry, a participant must complete a new agreement anytime they wish to change their election, including to start or stop deferring. All participants should complete an agreement even if they choose not to defer. A separate bonus election may be necessary. The plan sponsor should save all executed agreements, even prior agreements no longer in effect.
5For defined benefit plans, statements are required at least once every three years.
6If a DB plan is covered by the PBGC, then the plan is required to distribute the AFN in lieu of the SAR.



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