Important approaching deadlines Please make note of these important approaching deadlines for calendar year plans: December 1: Deadline for the submission of distribution forms for annual required minimum distributions (RMDs) that are due December 31 and for first year RMDs for individuals who turned 70½ during 2014 and must receive an RMD by April 1, 2015. Deadline for distributing the following annual notices for 2015 to participants: Participant fee disclosure* Safe harbor Qualified default investment alternative Automatic contribution arrangement Eligible automatic contribution arrangement Qualified automatic contribution arrangement * Participants and beneficiaries with the right to direct investment of assets in their account must receive a fee disclosure on or prior to the date they can first direct investments, then annually thereafter. New participant fee disclosures must be distributed 30-90 days prior to certain changes. December 31, 2014: Deadline for processing corrective distributions or for making qualified non-elective contributions and/or qualified matching contributions for 2013 nondiscrimination (i.e., actual deferral percentage and/or actual contribution percentage) test failures. Deadline to sign amendments that must be in place before the beginning of the 2015 plan year. Deadline for 2014 annual RMDs that are not first year distributions. If your plan has an anniversary date other than January 1, please make adjustments to the dates (except for dates related to excess deferrals) to coincide with your plan year. Under Internal Revenue Code section 7503, when a deadline falls on a weekend (i.e., Saturday or Sunday) or a legal holiday, the performance of such acts shall be considered timely if completed the next business day; however, corrective distributions should be processed the day before the weekend or legal holiday. Internal Revenue Service announces 2015 Cost of Living Adjustments (COLAs) for retirement plans The Internal Revenue Service (IRS) has announced COLAs for 2015. Note that some limits did not change. 2015 2014 401k/403b deferral limit: 401k/403b catch-up limit: 457 deferral limit: Governmental 457 catch-up limit: SIMPLE/SIMPLE 401(k) deferral limit: SIMPLE/SIMPLE 401(k) catch-up limit: Highly Compensated Employee (HCE) compensation threshold: Key employee/Officer compensation threshold: Benefit limit for defined contribution plans: Benefit limit for defined benefit plans: Maximum compensation: Social Security taxable wage base: $ $ $ $ $ $ 18,000 6,000 18,000 6,000 12,500 3,000 $120,000 $170,000 $ 53,000 $210,000 $265,000 $118,500 $ $ $ $ $ $ 17,500 5,500 17,500 5,500 12,000 2,500 $115,000 $170,000 $ 52,000 $210,000 $260,000 $117,000 Reminder: The $115,000 HCE compensation dollar limit for 2014 is used to determine HCEs in the 2015 plan year. For more information, visit http://www.irs.gov/Retirement-Plans and search on the term “COLA.” eActivity report changes and Payroll Feedback File reminder Our eActivity report, formerly known as the Participant Electronic Activity Report (PEAR), will be changing effective January 1, 2015. On January 1 the eActivity report will include updated address changes. Other eActivity data such as updated loans and contribution changes will no longer be reported on the eActivity report. eActivity data reported prior to December 31, 2014, will be available for historical purposes. Only new address changes will be added to the eActivity report beginning on 1/1/2015. The Payroll Feedback File has been available this year and offers more robust reporting for contributions and loans. This file is a comprehensive report that can be downloaded for your use or your payroll provider’s use for both contributions and loans. The Contribution report displays: Enrollment and updated contribution elections Deferral changes due to hardship withdrawals Automatic contribution arrangement data The Loan report displays: Loan initiation date Amount of loan Payment amount Term of loan Loan interest rate Payment frequency Number of payments Total of payments Final payment date Deemed default date (if applicable) We suggest you schedule your Payroll Feedback File with a selected date range and frequency (e.g. weekly, monthly, quarterly). The scheduled request allows you to include additional people to be notified when the report is produced. Reports are also available on demand using your chosen date range. The Payroll Feedback File and eActivity Report (to obtain address changes from participants) can be found under the Plan Reports tab on eSponsor. It's time to start planning for 2014 census submission On December 1, 2014, plan sponsors with a plan year-end of December 31, 2014, will receive an email announcing the due date for submitting the 2014 census. You must submit your census by the established due date to ensure testing and other year-end reporting services are completed timely. If your census is received after the due date, we will be unable to guarantee completion of your nondiscrimination testing by March 13, 2015. Actual deferral percentage (ADP)/actual contribution percentage (ACP) refunds distributed after March 13, 2015, are subject to a 10 percent Internal Revenue Service excise tax payable by the employer. If your plan has an eligible automatic contribution arrangement (EACA) provision in place, the due date whereby refunds will not incur an excise tax extends to June 30, 2015, provided the EACA applies to all employees, not just employees hired after the EACA provision was adopted. In addition, please take advantage of the tools available on the Year End Services Center on eSponsor. Finally, we encourage you to make plans to attend one of our Census Webinars offered. Details about the webinars will be announced at a later date. Updated Plan Administration Manual The Plan Administration Manual has a new look. Instead of individual chapters on eSponsor, you will find one searchable manual that contains a table of contents. In addition, the manual has links within the document to other sections of the manual as well as oneamerica.com We encourage you to use the Plan Administration Manual for reference and discuss any questions you have with your plan services consultant. Internal Revenue Service updates their compliance aids The Internal Revenue Service (IRS) has several tools available to help you keep your plan in compliance. There are one-page checklists available for: SIMPLE IRAs SEPs SARSEPs 401(k) plans 403(b) plans Each checklist contains a link to a Fix-It Guide that provides tips on how to find, fix and avoid many common errors. The format of each guide allows users to select and print only the mistakes they are interested in learning more about. The Fix-It Guides for all plan types were recently updated. We encourage you to visit the Retirement Plans page of the IRS website to learn more. Information for plans that use AUL for plan document preparation In preparation for plan year-end for calendar year plans and for your upcoming plan restatement, we have a few key dates and reminders for you to keep in mind. Year-end amendment deadline: For calendar year plans, amendment requests for plan changes that must be signed by year-end need to be submitted to the AUL home office no later than December 8, 2014, in order to ensure timely preparation of the plan amendment for your signature on or before December 31, 2014. Requests must be submitted through your assigned AUL transition consultant or plan services consultant. Examples of plan changes to be effective January 1, 2015, that need to be signed by year-end include, but are not limited to: Increasing contribution allocation requirements Changing the contribution allocation formula(s) Changing forfeitures from reallocation to reducing employer contributions or first paying plan expenses Changing the plan compensation definition Excluding employees from participation Increasing or decreasing plan eligibility requirements PPA restatement amendment freeze for plans currently on the prototype and volume submitter document: To ensure that all plan changes made by amendment are included in the upcoming PPA restatement, amendments must be signed by January 28, 2015. With this in mind, all amendment requests for calendar year plans that do not need to be signed prior to the beginning of the 2015 plan year (e.g., address or trustee changes) and amendment requests for plans with an anniversary date other than January 1 must be submitted to the AUL home office no later than January 19, 2015. This "amendment freeze" will remain in effect until you have signed your restated document. After you have signed your restated document, you may request an amendment to your plan. Contact your plan services consultant today to begin discussing any possible changes you would like to make. Timely remittance of employee contributions Plans that are subject to Title I of the Employee Retirement Income Security Act of 1974 (ERISA) must satisfy Department of Labor (DOL) requirements regarding the timely remittance of employee deferrals, after-tax contributions and participant loan repayments. Most profit sharing, money purchase, 401(k) and 403(b) plans are subject to Title I. There are a few types of plans that are exempt from Title I. These include 457(b) plans and church plans that have not elected to be subject to the minimum eligibility and vesting requirements of ERISA and the Internal Revenue Code. The purpose of the DOL regulations regarding the timing of depositing employee contributions (including deferrals) and payroll-deducted loan repayments into a qualified retirement plan trust is to ensure that the funds are being invested in the plans rather than remaining in the employer’s general corporate funds. The DOL regulations contain a safe harbor period for remitting employee contributions and loan repayments for small retirement plans (plans with fewer than 100 participants at the beginning of the plan year). Under this safe harbor period, employee contributions and loan repayments to a small plan will be deemed to have been timely remitted if those amounts are deposited to the plan within seven business days after they were received or withheld by the employer. Of course, sponsors of small retirement plans may make deposits before the end of the seven day period. The current deposit rules for large retirement plans (plans with 100 or more participants at the beginning of the plan year) state that the employer must transmit employee contributions and loan repayments to retirement plans as soon as they can reasonably be segregated from the general assets of the employer. The DOL has determined that in some instances, employee contributions including deferrals and loan repayments can reasonably be segregated within two business days of receipt or withholding by employers. If the employee plan withholdings are not remitted in a timely fashion, the employer is treated as having engaged in a prohibited transaction with respect to the late remittances and must pay an excise tax. The employer is also responsible for the investment losses due to the late deposits. Please view Timing of retirement plan contributions for additional information. Managing beneficiary designations Life events such as death, marriage (including legally recognized same-gender marriages), divorce and/or birth or adoption of children may require a change in beneficiary designations. It’s a good idea to remind your participants to review their beneficiary designations and make changes to ensure that designations align with their wishes. In addition, before you approve a distribution following the death of a participant, you may want to verify that there are no other parties that may claim rights to the benefit. Participants and sponsors can add, change and view beneficiary designations via our secure Account Services and eSponsor websites. Advantages include: Ease your administrative burden in tracking beneficiaries. Participants can manage their beneficiary designations online. This reduces paper management and allows participants to review beneficiary elections at any time. Offer you reporting on beneficiary designations. A Participant Beneficiary Designation report is available under the Plan Reports tab. If participant beneficiary data has been added to our system you will be able to view beneficiary designations in the report. You will also be able to review beneficiary designations under the Participant Data tab. Beneficiary designations can be made during eEnrollment and via the My Profile tab on Account Services. Entering beneficiary designations is a step-by-step process which includes participant communications and spousal consent when necessary. Further, plans subject to Qualified Pre-retirement Survivor Annuity (QPSA) will receive additional information for participants through the beneficiary election process. Distributing annual notices and participant fee disclosures If your plan design requires an annual notice to participants, notices must be distributed at least 30 days prior to the beginning of the next plan year. Therefore, December 1, 2014, is the deadline for calendar year plans. Examples of plan design features that require an annual notice include: Safe harbor 401(k) plans Automatic contribution arrangements (ACAs) Qualified automatic contribution arrangements (QACAs) Eligible automatic contribution arrangements (EACAs) Qualified default investment alternative (QDIA) Participant fee disclosures Your plan may contain more than one of the features indicated above and may require multiple notices. It is important to note that the safe harbor notice language may not be combined with any other notice, but may be distributed to your participants at the same time you distribute any other notice. Participant fee disclosure information: As a reminder, under section 404(a)(5) of the Employee Retirement Income Security Act of 1974 (ERISA) regulations, employers must deliver participant fee disclosures "On or before the date on which a participant or beneficiary can first direct his or her investments and then annually thereafter" and the regulation defines "annually" as being "at least once in any 12-month period, without regard to whether or not the plan operates on a calendar or fiscal year basis." In addition, new participant fee disclosures must be distributed 30-90 days prior to certain changes. Participants may access the participant fee disclosure document in Account Services under the My Plan tab; however, posting on Account Services does not constitute delivery. Guidance provided by the Department of Labor (DOL) regarding its participant fee disclosure regulation requires that comparative charts of investment-related information provided by multiple service providers or investment issuers either be consolidated for participants and beneficiaries into one document or be delivered to them at the same time in a single mailing or transmission. If you don't file your Form 5500, Form 5500-SF or Form 8955-SSA by the due date If you filed your Form 5500, Form 5500-SF or Form 8955-SSA after the filing deadline, you will receive a CP 283 (5500) or CP 283C (8955-SSA) Notice from the Internal Revenue Service (IRS). It is very important that you respond to the IRS before the date listed on the notice even if you think that you received the letter in error. The IRS penalties for late filings are: Form 5500 filing - $25 per day up to a maximum of $15,000 Form 8955-SSA - $25 per day There are separate penalties that may be assessed by the IRS and/or Department of Labor (DOL) for failure to file a Form 5500 filing and/or a Form 8955-SSA (if required). If you do not file your Form 5500, Form 5500-SF or Form 8955-SSA, you will receive a CP 403 Notice from the IRS approximately 15 months after the original due date. It is very important that you respond within the 30-day window for response even if you think that you received the letter in error. If you do not respond timely, you will receive a CP 406 Final Notice which also has a 30-day response window. The IRS has published Understanding Your CP 403 or CP 406 Notice that addresses common questions and provides guidance to help you draft a response Don't wait until you receive a CP 403 Notice to act. Remember the Department of Labor's Delinquent Filer Voluntary Compliance Program (DFVC), which provides plan administrators an opportunity to pay reduced penalties. In addition, there is IRS Notice 2002-23, which provides relief from penalties for late filers who are eligible for the DFVC program. The Form 5500 filed with the DOL can be viewed at http://www.efast.dol.gov/welcome.html. The best way to search is by entering your EIN. Resources to help your participants learn the basics of solid retirement preparation With the average life expectancy increasing, uncertainty around Social Security and inflation continuing to erode the purchasing power of money, participating in a retirement plan is more important than ever. By sponsoring a retirement plan, you are putting your employees on a good path, but it’s up to them to take advantage of this important benefit. We have the tools and resources you need to motivate your employees to start on the path to retirement readiness. Everyone has moments when they have thought, “I’ll get to that one day” or “One day I will figure it out.” This can be an especially easy mindset to fall into when it comes to preparing for retirement. We want to show your employees that “one day” is today. One Day is Today® is a multi-channel communication curriculum designed to educate your current and potential plan participants in a way that is relevant to them. The program features five categories, each with its own distinct, color-coded icon, to make it easy to create a campaign of materials specific to the needs of different employees and plan participants. The five categories are: Getting started Retirement 101 Investments Personal finance Nearing retirement Retirement 101 Knowledge is power. The materials in the Retirement 101 section of the One Day is Today® website are designed to educate employees who may be getting started with retirement preparation and its fundamentals. The Retirement 101 tools help participants begin their retirement preparation efforts and teach them how to work toward their financial and retirement goals. A series of articles help participants understand the benefits of tax deferral, things to consider before taking a loan from their retirement account and how to check their retirement preparation progress. Interactive calculators help employees see how small changes today can add up to increased savings in the future. Finally, videos are available to explain concepts such as investing, withdrawal strategies and diversification. It’s about more than retirement Many of your employees are likely feel challenged by competing financial obligations – saving for a new home or mortgage payments, college tuition or debt. Because retirement is a long-term financial goal, it sometimes takes a back seat to more immediate financial needs. As a plan sponsor, you can help your participants improve their overall financial wellness by providing information that empowers participants to prepare for retirement while managing their short-term financial obligations. On the One Day is Today® website, you’ll find a wide variety of guides, podcasts and videos from Peter Dunn a.k.a. “Pete the Planner.” Pete the Planner adds a face and a voice to our One Day is Today® participant communication and education program and turns concepts often perceived as boring, foreign or intimidating into fun and informative experiences. These materials complement the One Day is Today® materials by tying overall financial wellness to your employees’ retirement readiness. Several Pete the Planner materials address topics that are important to your participants who are just beginning their retirement preparation and act as a complement to the One Day is Today® Retirement 101 materials. Pete’s guide for starting late with retirement preparation helps participants who may be beginning to set their retirement goals later in their career. Entertaining videos help explain basic retirement plan design concepts, such as matching contributions. Employees who are on the go can take advantage of Pete’s materials, too. Your employees can download podcasts and learn about topics such as plan fees and working with a financial professional any time. If you are looking to help your participants set achievable goals that will provide the foundation on which they build their financial future, be sure to check out the One Day is Today® Retirement 101 resources today. Celebrate your retirement plan Are you looking for a new, interactive way to engage your employees and increase awareness and participation in your company’s retirement plan? Consider planning a day to celebrate and promote your retirement plan among your employees. The first step is to create a strategy. Consider whether you want to dedicate the event exclusively to your retirement plan. This can be beneficial because it puts the spotlight on the plan and its benefits. Alternatively, employees often like to think about all of their benefits at one time. Consider doing something special to highlight your retirement plan in conjunction with open enrollment for your other benefit plans. Some other types of events you may want to consider include: A lunch-n-learn: Employees can participate in a presentation over the lunch hour. Consider providing lunch or other refreshments. A presentation: Offer the presentation over several days and times so employees can easily work it into their schedules A benefits fair or booth: Employees can stop by when they are available. A webcast: This works well if you have an online workforce or multiple locations. Next, think about the best ways to prepare for your event. Will your event take place on one specific day? Or will you plan a series of events over a week – or even throughout the year? However you decide to celebrate, you’ll need to let your employees know. There are several ways you can create some buzz around your event, including: Employee Intranet site Email Internal newsletters Bulletin boards in break rooms and cafeterias Message from an executive Desk drop Voicemail blast Finally, consider tying a contest or giveaway to your event. Raffles and trivia games are great ways to get employees involved and have some fun. Use your imagination; no matter what form your event takes, the ultimate goal of hosting an event to celebrate your retirement plan is to show your employees how important the plan is to their financial future. OkTargeted communications coming soon! The transition and enrollment processes are our first opportunity to establish a relationship with and to encourage employees to participate in their retirement plan. Understanding this, we’re excited to introduce new targeted communication materials aimed at reaching your employees with the right information at the right time. Transition FAQ Brochure – This targeted communication is an initial touch point for employees in plans transitioning to OneAmerica. The piece introduces OneAmerica as the new provider and provides high-level information on what to expect during the transition process. Employees already participating in the plan will receive this document in place of an enrollment kit, which is intended to educate employees on the reasons they should participate in the plan. If your company is in the process of acquiring another company, or in the future acquires another company, your relationship manager will work with you on how this piece can be used as part of the onboarding process. Investment Change Notice – This targeted communication supports situations where you are substantially changing your plan’s investment line-up and want to announce the change to your employees and encourage them to take action based on the new investment lineup. Quick Enrollment Mailer – This targeted communication is aimed at increasing participation by targeting employees who are eligible to participate but are not currently participating in the plan. Working together with your relationship manager, this piece should be used as part of a focused campaign. Meeting Posters – While the concept and availability of meeting posters is not new, you now have the option of ordering posters pre-populated with meeting date, time and location. Please note that you will still have the option of ordering blank posters – where date, time and location can be added by you – if you prefer.
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