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2021 Compliance Calendar

January

15th

Provide/Confirm prior year census data

 

31st

Deadline: Sending Form 1099-R to participants who received distributions during previous year*

February

15th

Review/Approve compliance testing results

 

28th

Deadline: Filing Form 1099-R with IRS to report distributions made in previous year Deadline for electronic filing is March 31*

March

15th

Deadline: ADP/ACP test corrective distributions to avoid excise taxes, unless EACA for full year 2019

 

Note: A special deadline may apply to plans that satisfy the requirements of an eligible automatic contribution arrangement (EACA). See “June”

 

Deadline: Filing partnership tax returns and contribution deadline for deductibility (without extension) for companies operating on calendar0year fiscal year

 

Deadline: Requesting automatic extension to September 15 for partnership tax returns

 

31st

Deadline: Electronic filing of Form 1099-R to report distributions made in previous year

April

1st

Required: Beginning date for participants attaining age 72 or retiring after age 72 in prior year

 

Deadline: Taking first required minimum distribution (RMD) under Internal Revenue Code (IRC) Section 401(a)(9)**

 

15th

Deadline: Processing corrective distributions for IRC Section 402(g) excesses

 

Deadline: Filing individual tax returns

 

Deadline: Contribution deadline for deductibility for self-employed individuals (without extension)

 

Deadline: Requesting automatic extension to October 15 for individual and corporate tax returns

June

30th

Deadline: processing corrective distributions for failed ADP/ACP test from plan with EACA without 10% excise tax (if applicable)

July

29th

Deadline: Sending Summary of Material Modification (SMM) (210 days after end of plan year in which the amendment was adopted)

 

31st

Deadline: Filing Form 5500 (without extension)

 

Deadline: Filing Form 5558 to request automatic extension of time to file Form 5500 (to October 15)

 

Deadline: Filing Form 5330—Return of Excise Taxes Related to Employee Benefit Plans-used to report and pay excise taxes on prohibited transactions and excess 401(k) plan contributions that occurred in prior year

September

15th

Extended deadline: Filing tax returns for partnerships

 

Final deadline: Contribution deadline for deductibility for calendar-year partnerships and S-corporations

 

30th

Deadline: Distributing Summary Annual Report (SAR) to participants, unless deadline for Form 5500 was extended, then two months after due date for Form 5500 (December 15)

October

15th

Deadline: Adopting a retroactive amendment to correct an IRC Section 410(b) coverage or IRC Section 401(a)(4) nondiscrimination failure

 

Extended deadline: Filing Form 5500

 

Extended deadline: Individual and/ or corporate tax returns and final contribution deadline for deductibility for these entities

December

1st

Deadline: Sending annual 401(k) and safe harbor match notice

 

Deadline: Sending annual QDIA, qualified default investment alternative notice

 

Deadline: Sending annual automatic contribution arrangement notice (ACA)
For administrative ease, a combined notice may be provided for the above notices

 

15th

Extended deadline: Distributing SAR to participants

 

31st

Deadline: Processing corrective distributions for failed ADP/ACP test with 10% excise tax

 

Deadline: Correcting a failed ADP/ACP test with qualified nonelective contributions (QNECs)

 

Deadline: Amendment to convert existing 401(k) plan to safe harbor design for next plan year (provided notice requirement is met)

 

Deadline: Amendment to remove safe harbor status for next plan year

 

Deadline: Amending plan for discretionary changes implemented during plan year (certain exceptions apply)

*The deadlines in this calendar are for plans with calendar-year plan years.

 

**The CARES Act provides a waiver of RMD’s for defined contribution plans and IRAs for 2020.

Reminder: Required fee disclosures

Plan Sponsor

Initial disclosure: Required within a reasonable period before the contract is entered into or renewed

Annual disclosure: Required following changes in investment information

Additional disclosures: Required no later than 60 days after the effective date of the change for changes in compensation or services provided

Participant

Initial disclosure: Required on or before the date when participants can first direct investments

Annual disclosure: Required to be updated and distributed at least annually

Additional disclosures: Required at least 30 days, but no more than 90 days, prior to certain plan changes

Highland maintains important disclosures about its status as a Registered Investment Advisor with the SEC in its Form ADV Part 2.

 

This information was developed as a general guide to educate plan sponsors and is not intended as authoritative guidance or tax/legal advice. Each plan has unique requirements and you should consult your attorney or tax advisor for guidance on your specific situation.