Upcoming Compliance Deadlines

The CARES Act gives the DOL the authority to delay deadlines due to public health emergencies. The dates below are in effect as of the date of this publication.

April 2020

1st: Required Minimum Distributions – Regulations require that a participant must receive a required minimum distribution (RMD) by April 1st of the year following the year in which the participant attains age 70 ½ (changed to age 72 for 2020). WAIVED per the CARES Act for 2020.

15th: Excess Deferral Amounts – Salary deferral contributions in excess of the IRS-issued limits in any calendar year ($19,000 for 2019), must be returned to the participant (plus earnings) by April 15 of the year following the year in which the excess occurred. Deadline currently NOT extended.

15th: Employer Contributions – Deadline for contributing employer contributions for amounts to be deducted on 2019 C corporation and sole proprietor returns (unless extended). Deadline extended by the CARES Act to July 15, 2020.

May 2020

15th: Deadline to supply participants with the quarterly benefit/disclosure statement including plan fees and expenses charged to individual plan accounts during the first quarter. Deadline currently NOT extended.

June 2020

30th: EACA ADP/ACP Corrective Testing – ADP/ACP refunds are due to highly compensated employees (HCEs) to avoid a 10% excise tax on the employer for plans that have elected to participate in an Eligible Automatic Enrollment Arrangement. Deadline currently NOT extended.

July 2020

15th: Defined Benefit Contributions – Single employer DB plans were provided relief under the CARES Act for any required contributions (both quarterly and year end contributions) during 2020. Extended to January 1, 2021.

28th: Summary of Material Modifications (SMM) – A SMM is due to participants no later than 210 days after the end of the plan year if a change or amendment was adopted in that year. Deadline currently NOT extended.

31st: Due date for calendar-year plans for the filing of Form 5500, Form 5558, Form 5330, and Form 8955. Deadline currently NOT extended.

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