Our industry is full of deadlines. Today was the due date for a special filing to report the status of terminated participants in qualified retirement plans, and whether those participants had money due to them or if they had already been paid. This information is reported on a new form called 8955-SSA. After this special filing, the 8955 will be submitted on the Form 5500 due date (see below).
Fixed Dates
Some due dates are fixed, meaning that they always happen on a particular date every year. Examples of fixed dates are:
| Form 1099R | January 31 | report distributions from retirement plans in the prior year |
| Form 1096 | February 28 | cover page for submitting Forms 1099R |
Rolling Dates
Most dates relating to due dates for retirement plans are dependent on the Plan Year. The majority of plans are administered on a calendar year, but a good portion is administered on a fiscal year. Very often if the company that sponsors a plan has a fiscal year, then the plan may be run on that same fiscal year. A list of the rolling due dates for a retirement plan is shown below. All dates relate to the end of the plan year.
| Compliance corrections (if necessary) | 2 ½ months after end of plan year |
| Contributions for deduction purposes | 2 ½ months for corporations, 3 ½ months for others |
| Contributions may be extended for | 6-months after initial deadline |
| Mandatory contributions | 8 ½ months after end of plan year |
| Form 5500 due date | 7 months after end of plan year |
| Form 5500 may be extended for | 2 ½ months after initial deadline |
| Participant notices | 30-90 days prior to the effective date (Safe Harbor status, Automatic Enrollment materials and/or Qualified Default Investment Arrangement) |
| Plan Amendments | In general amendments must be signed before they are effective |
We encourage all of our clients to have these due dates on their calendar, with a reminder at least 30-days in advance.
Not sure you are getting what you need from your TPA? (An indication may be that you are here rather than on the phone with them.) We can look at your latest 5500 and give you insight.
Corrections
There is a way to fix the problem of failing to meet a deadline as outlined here.
| Compliance corrections (if necessary) | Can be corrected up through the end of the following plan year |
| Contributions | May be made up through the end of the following plan year, but changes to the timing of the contribution will change the timing of the tax deduction |
| Form 5500 due date | You can file under the Delinquent Filer Voluntary Compliance program for a fee of $750 for a small plan, or $1,500 for a plan with over 100 participants. |
| Participant notices | Failure to provide notices timely can be very expensive; up to $100 per day per participant! |
| Plan Amendments | The Employee Plans Compliance Resolution System includes ways to retroactively amend plans and make other corrections that may be needed. These submittals typically require the expertise of an attorney who specializes in ERISA law. |
As your Third Party Administrator, we may nag you to get us your work on time. But given the way that our industry is wired with due date after due date, we want to make sure that you are in compliance at all times. Please call us if you ever have a question about your plan or an upcoming deadline.
You deserve a TPA that will answer all your calls and questions, not one that leaves you looking online for answers elsewhere. Request your Proposal to see how we can serve you better.
