Reporting & Disclosure Calendar for Cash Balance & Other Defined Benefit Plans

 

Date & Deadline

Deadline Description

January

January 1

Annual Valuation Date for Large Plan Filers

 For plans with more than 100 participants, data for the January 1 valuation must reflect the participant and asset census as of the same date, requiring plan sponsors to submit the data to the valuation actuary in a timely manner to enable compliance with the statutory reporting dates in this calendar. 

January 15

Q4 Quarterly Contribution

Due date for the fourth quarter quarterly contribution for the previous calendar year for plans with quarterly payments, either through cash contributions or a signed election to use available carryover/prefunding balances.

Note: If this contribution is missed by more than 30 days, PBGC Form 10 (Post-Event Notice of Reportable Events) is due no later than February 14. Additionally, a failure to satisfy the requirement within 60 days of this due date may trigger, if applicable, a requirement to notify participants, beneficiaries, and alternative payees.

January 31

Form 1099-R

Required to be provided to all participants who received a distribution in the previous year.  The filing to the IRS is due by February 28.

February

February 28

PBGC Form 1-ES

Pension Benefit Guaranty Corporation (PBGC) Form 1-ES is due for plans with over 500 participants and is based on the estimated flat-rate premium for the current year.

March

March 15

Minimum Funding Waivers

Plan sponsors requesting a funding waiver for the current year must do so by March 15th.

March 15

Deductible Contribution Deadline

 

Plan sponsors that are partnerships and S-corporations must make contributions by March 15 to deduct for the prior tax year (unless the tax deadline is extended).

For more information on the deductible contributions, click here.

March 31

AFTAP Certificate (1st Deadline)

First deadline for the Adjusted Funding Target Attainment Percentage Certificate. If not completed, deemed prior year’s AFTAP percentage minus 10%.

Note: If deemed AFTAP is less than 80%, plan distributions are limited to 50% of the lump sum value.  If less than 60%, any installment payments greater than monthly annuities are prohibited and benefit accruals are frozen.

April

April 1

Required Minimum Distribution

 
For participants attaining age 70 ½ during the preceding calendar year, the initial required minimum distribution is due by April 1. Non-owners who continue working may defer RMDs until April 1 of the year after they actually retire. Participants must also receive ongoing payments for any prior elected annuity streams.

April 15

Deductible Contribution Deadline

Plan sponsors that are C-Corporations or Sole Proprietorships must make contributions by April 15 to deduct for the prior tax year (unless the tax deadline is extended).

For more information on the deductible contributions, click here.

April 15

Q1 Quarterly Contribution

 

Due date for the first required quarterly contribution for the calendar year for plans with quarterly payments, either through cash contributions or a signed election to use available carryover and/or prefunding balances.

Note: If this contribution is missed by more than 30 days, PBGC Form 10 (Post-Event Notice of Reportable Events) is due no later than May 14. Additionally, a failure to satisfy the requirement within 60 days of this due date may trigger, if applicable, a requirement to notify participants, beneficiaries, and alternative payees.

April 30

Large Plan Annual Funding Notice Delivered

 

The Annual Funding Notice for large plan Form 5500 filers must be delivered to all participants by this date.

April 30

101(j) Notice Delivered

 

Deadline for the delivery of the 101(j) Notice notifying participants if any restrictions apply. This notice is triggered by any April 1 AFTAP presumptions.

July

July 15

Q2 Quarterly Contribution

Due date for the second required quarterly contribution for the calendar year for plans with quarterly payments, either through cash contributions or a signed election to use available carryover and/or prefunding balances.

Note: If this contribution is missed by more than 30 days, PBGC Form 10 (Post-Event Notice of Reportable Events) is due no later than August 14. Additionally, a failure to satisfy the requirement within 60 days of this due date may trigger, if applicable, a requirement to notify participants, beneficiaries, and alternative payees. 

July 29

Summary of Material Modifications

Due 210 days after the plan year in which the change was made. 

July 31

Form 5500 & Form 8955-SSA (Unless Extended)

The Form 5500 and Form 8955-SSA must be electronically filed with the Department of Labor via the EFAST2 system no later than July 31 of the following year.

Note: The deadline for both forms can be extended to October 15 by filing Form 5558 by the July 31 deadline. For non-calendar year plans, the deadline is seven months following the last day of the plan year. For more information on Forms 5500 and 8955-SSA, click here and here.

September

September 15

Final Funding Deadline for Prior Plan Year Contribution

 

Due date to make the final contribution to satisfy the minimum funding requirements for the prior plan year.

Note: If the minimum required contribution requirements are not met by September 15, IRS Form 5330 and payment of a 10% excise tax must be filed.  PBGC covered plans must file Form 10 by October 15. There is no Form 10 small plan waiver for missing the minimum funding deadline.

September 30

Summary Annual Reports

 Summary Annual Report (SAR) is due for the previous year.

September 30

AFTAP Certificate (2nd Deadline)

 Second deadline for the Adjusted Funding Target Attainment Program Percentage Certificate. If not completed, deemed prior year’s AFTAP percentage minus 60%. If not completed, AFTAP is deemed to be 60% and the plan is deemed frozen, lump sum restrictions apply.

October

October 15

Q3 Quarterly Contribution

 

Due date for the third required quarterly contribution for the calendar year for plans with quarterly payments, either through cash contributions or a signed election to use available carryover and/or prefunding balances.

Note: If this contribution is missed by more than 30 days, PBGC Form 10 (Post-Event Notice of Reportable Events) is due no later than November 14. Additionally, a failure to satisfy the requirement within 60 days of this due date may trigger, if applicable, a requirement to notify participants, beneficiaries, and alternative payees.

October 15

Form 5500 & Form 8955-SSA (Extended Deadline)

The Form 5500 and Form 8895-SSA must be electronically filed with the Department of Labor via the EFAST2 system no later than October 15 if the deadline has been extended via timely filing of Form 5558 (by the July 31 deadline.)

For more information on Forms 5500 and 8955-SSA, click here and here.

October 15

Corrective Plan Amendment

 

Deadline to adopt a retroactive corrective plan amendment, if the plan fails minimum coverage, nondiscrimination, and/or compensation requirements for the prior plan year.

October 15

Small Plan Annual Funding Notice Delivered

 The Annual Funding Notice for small plan Form 5500 filers must be delivered to all participants by this date for PBGC-covered plans. For non-PBGC plans the usual SAR is needed.

October 15

PBGC Premium Filing and Payment

PBGC premium filing and payment due for the current year.

October 30

101(j) Notice Delivered (Late AFTAP Certification)

 Deadline for the delivery of the 101(j) Notice notifying participants if any restrictions apply. This notice is triggered by the failure to certify the AFTAP timely.

December

December 15

Summary Annual Report

 Deadline for Summary Annual Report (SAR) if corporate extension is filed.

December 31

Discretionary Amendment

Deadline for the adoption of a discretionary amendment for the current year.

December 31

Annual Benefit Statement Availability Notice

 Provide an annual notice to participants about the availability of and the means to obtain a pension benefit statement.


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