A recently issued notice from the Department of Labor, “Notice” 2020-01 provides timely relief for retirement plan disclosures required under ERISA. This includes disclosures such as:
- individual benefit statements
- terminated vested notices
- summary plan description
- summary of material modifications
- blackout notices
- qualified investment alternative notices
- automatic contribution arrangement notices
- participant-directed accounts disclosures, as well as
- fee disclosures.
The relief is provided if the plan sponsor acts in good faith by communicating through various means (i.e. email, mail, etc.) with participants.
There are other administrative and procedural guidelines related to processing of plan participant activity. These guidelines address timely payment of employee contributions and loan repayments, as well as obtaining documents over loan requests. Due to COVID-19, untimely payments or incomplete loan documentation that are delayed will not be considered a violation as long as the plan sponsor demonstrates:
- a conscientious good faith effort to remit payments
- correct any deficiencies and obtain documentation within a reasonable time period, or
- when administratively it could be accomplished.
At this time, there is no relief for calendar year plans for the filing of the IRS Form 5500 by July 31, 2020.
For more information, please contact us at 401-831-0200.