December Plan Deadlines

Checklist of December Plan Deadlines for Retirement, Medical, and Other Plans

November 30, 2021

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Fulcrum Partners is pleased to share the following report, prepared by the Employee Benefits group at Isler Dare PC: Checklist of December Plan Deadlines for Retirement, Medical, and Other Plans.

As we enter December, we wanted to remind you of some key deadlines for benefit plans.

Deadline December 2, 2021

  • Distribute 401(k)/403(b) plan notices, including the QDIA[i] notice, safe harbor notice, and auto enrollment notice

Deadline December 15, 2021

  • Distribute Summary Annual Reports for retirement plans, and for health and welfare plans with more than 100 participants (assuming Form 5558 was filed to extend due date for Form 5500)

Deadline December 27, 2021

  • Deadline for first report on group health prescription drug cost and benefits required under CAA-21[ii]

Deadline December 31, 2021

  • Adopt plan amendments for discretionary plan changes that took effect during 2021, and interim amendments required by statute or regulations to be adopted by year-end
  • Confirm retirement plan recordkeepers have paid annual required minimum distributions (RMDs)
  • Process corrective distributions to “cure” failed ADP/ACP[iii] [iv] tests for 2020 with payment of 10% excess tax
  • Provide defined benefit pension plan participants with an annual notice about the availability of pension benefit statements, or provide participants with an annual notice about the availability of (and the means to obtain) the pension benefit statement for 2021 if the alternative notification approach is being used in 2021
  • Correct FSA and DCAP [v] [vi] discrimination testing failures that occurred in 2021
  • Deadline for correcting top-heavy testing failures that occurred in 2020
  • Provide eligible ESOP [vii] participants with notice about their rights to diversify a portion of their ESOP accounts
  • Deadline for safe harbor plan to remove its safe harbor status for the following year; for an existing defined contribution plan to convert to a safe harbor plan (other than a non-elective safe harbor plan); or to elect safe harbor status for the prior plan year with a nonelective contribution of 4% or more of compensation
  • Deadline for actuary’s certification of 2021 AFTAP [viii] to prevent presumed AFTAP of less than 60% from applying January 1, 2022 (or retroactively to October 1, 2021, if range certification issued prior to October 1, 2021)

Special Projects

  • Remind employees and participants to review and elect aged-50-and-over catch-up contributions in 401(k)/403(b) plans, to be effective January 1, 2022
  • Notify employees of cost of living increases in regular and catch-up contribution limits in 401(k)/403(b) plans, to be effective January 1, 2022
  • Work with finance and payroll departments to set up internal systems to reflect retirement plan contribution and compensation limits for 2022

[i] Qualified Default Investment Alternative

[ii] Consolidated Appropriations Act

[iii] Actual Deferral Percentage

[iv] Actual Contribution Percentage

[v] Flexible Spending Arrangement

[vi] Dependent Care Assistance Program

[vii] Employee Stock Ownership Plan

[viii] Adjusted Funding Target Attainment Percentage

This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, accounting, legal or tax advice. Any tax advice contained herein is of a general nature. You should seek specific advice from your tax professional before pursuing any idea contemplated herein.

Securities offered through Lion Street Financial, LLC (LSF) and Valmark Securities, Inc. (VSI), each a member of FINRA and SIPC. Investment advisory services offered through Lion Street Advisors, LLC (LSA) and Valmark Advisers, Inc. (VAI), each an SEC registered investment advisor. Please refer to your investment advisory agreement and the Form ADV disclosures provided to you for more information. VAI/VSI and LSF/LSA are non-affiliated entities and separate entities from OneDigital and Fulcrum Partners.

Unless otherwise noted, VAI/VSI, LSF/LSA are not affiliated, associated, authorized, endorsed by, or in any way officially connected with any other company, agency or government agency identified or referenced in this document.

Lion Street Advisors // Lion Street Financial

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