401(k) Plan Calendar Deadlines by Jessica Smith, APA
401(k) plan calendar deadlines should be marked on every plan sponsor’s calendar or iPhone. Did you know a deadline was originally a line drawn around a prison beyond which prisoners were liable to be shot? It is no wonder so many of us instinctively shrink from the word! And, if you work with a qualified retirement plan, you know the term “401(k) plan deadline” gets thrown around often.
But there’s hope! Just as the definition of “deadline” has transformed, so too can alter your reaction to impending 401(k) plan calendar deadlines. Below, you will find an outline of the major events during a typical 401(k) plan calendar year. This should assist you, so you can be prepared, complete tasks in advance, and never have to fear the deadline again. These are the most important deadlines during the year; however, you should keep in touch with your third party administrator and accountant to be sure that the plan deadlines relating to your particular plan are properly met.
Forms 1099R must be provided to participants who received distributions during the prior calendar year.
February 28 (or, in a leap year, 29)
Forms 1099R and the transmittal Form 1096 must be filed with the IRS in relation to distributions paid by the plan during the prior calendar year.
The first annual tax deadline for corporate and partnership filers also aligns with the date corrective distributions must be processed for a calendar plan year (i.e., one that ends on December 31st). Corrective distributions for failed nondiscrimination (ADP/ACP) testing must be processed within 2½ months after the plan year-end to avoid the plan sponsor being subject to a 10% excise tax.
This is also the deadline for depositing employer contributions that are to be deducted on the tax returns that are due on this date unless the returns are being extended.
Participants who attained age 70½ in the prior calendar year must begin taking required minimum distributions from the plan by this date if (a) the participant owns more than 5% of the plan sponsor; or (b) the participant has retired from the company.
The personal tax filing deadline aligns with the date distributions of excess deferrals under Internal Revenue Code (“Code”) Section 402(g) (that is, distributions of amounts in excess of the $18,500 limit for 2018 ($24,500 for those age 50 and over)) must be processed.
This is also the contribution due date for self-employed individuals who file their tax returns on this date unless the returns are being extended.
If the 401(k) plan is an “eligible automatic contribution arrangement” (EACA) – that is, a certain type of plan that has automatic enrollment of its participants—this is the extended deadline for corrective distributions due to failed nondiscrimination testing to avoid excise taxes.
This is the filing deadline for Forms 5500, 5500-SF, and 5500-EZ for calendar year plans. . (These forms must be filed within 7 months after the plan year-end unless a timely extension is filed.) If the due date for these returns is to be extended, file Form 5558 by this date. This is also the deadline for Forms 5330 (payment of excise taxes) and 8955-SSA (to report terminated vested participants).
The Summary Annual Report is due to be distributed to participants in a calendar year plan for the prior year. (Summary Annual Reports must be provided to participants within 9 months after the plan year-end.)
This is the extended filing deadline for Forms 5500, 5500-SF, and 5500-EZ for a calendar year for the prior year if Form 5558 was filed by the initial due date. (These forms that are on extension must be filed within 9½ months after the plan year-end.)
This is the deadline for annual Safe Harbor, QDIA, and automatic enrollment notices to be provided to the employees eligible for the calendar year plans for the following year. (These annual notices must be provided at least thirty days prior to the start of a new plan year. Special deadlines apply to employees when they first become eligible.)
If the deadline for the Form 5500 (or 5500-SF or 5500-EZ) was extended, the due date for the Summary Annual Report is also extended until 2 months after the extended deadline for the appropriate form. (The extended Form 5500 deadline is 9½ months after the plan year end, so the extended deadline of the related Summary Annual Report is 11½ months after the plan year).
This is the last day of a calendar-year plan, which is the deadline for plan amendments if your plan must be amended for changes in the way it has been administered during the year. Exceptions to this deadline are changes relating to modifications made by the government in legislation, regulations, or other guidance.
Now you can be sure to have your 401(k) plan calendar deadlines marked on every one of your calendars – paper, plastic, and electronic – for the upcoming year! If you have additional questions, be sure to contact your third-party administrator or the National Institute of Pension Administrators (NIPA).
Jessica Smith, APA, is an Analyst Manager at Sunwest Pensions in Tempe, Arizona.
Jessica has been working in the retirement industry since 2008. Soon after receiving a Bachelor of Arts degree in English Literature from the University of Pittsburgh, she learned the ropes working as the third-party administrator for the retirement plan of one of the United States’ largest unions. Jessica has been with Sunwest Pensions since 2011 and holds a NIPA Accredited Plan Administrator (APA) designation.