Expanded reporting and disclosure requirements Single-employer pension plans under ERISA

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1 2019 Expanded reporting and disclosure requirements Single-employer pension plans under ERISA Table of Contents Reporting Requirements 1 Disclosure Requirements 4 Individual Deferred Vested Pension Statement () IRS Form 1099-R () 1 Annual Funding Notice () 4 Notice of Receipt of Domestic Relations Order () IRS Form 5558 () 1 Summary Annual Report (SAR) () 4 Notice of Suspension of Benefits () 9 Form 5500 (including applicable schedules and attachments) () 1 Summary of Material Modification (SMM) () 4 Notice of Significant Reduction in Rate of Future Benefit Accrual (/MPPP) IRS Form 8955-SSA () 1 Summary Plan Description (SPD) () 4 Rollover Notice () 10 Notice of Qualified Separate Lines of Business (QSLOBs) () Plan Merger, Consolidation, or Transfer of Assets or Liabilities () 2 Periodic Benefit Statement () 4 Explanation of Qualified Preretirement Survivor Benefit (/MPPP) 2 Periodic Benefit Statement () 5 Explanation of Qualified Joint and Survivor Annuity (QJSA); Financial Effect and Relative Values of Optional Forms of Payment (/MPPP) Comprehensive PBGC Premium Filing () 2 401(k)/(m) Safe Harbor Notice () 5 Notice of Right to Defer a Distribution and Notice of Consequences of Failing to Defer () PBGC Reporting for Substantial Underfunding () 2 Updated 401(k)/(m) Safe Harbor Notice for Mid-Year Changes () Reportable Events () 2 401(k)/(m) Safe Harbor Discontinuance Notice () Notice of Failure to Make Required Contributions of More than $1 Million () 3 Automatic Contribution Arrangement Notice (QACA) (EACA) () Substantial Cessation of Operations () 3 Notice of Qualified Default Investment Alternative (QDIA) () Notice of Withdrawal of a Substantial Employer from a Multiple Employer Plan () 3 Notice of Qualified Change in Investment Options (QCIO) () 6 Notice of Failure to Meet Minimum Funding Standards () 6 Notice of Funding-Based Limitations on Plan Distributions () 6 Notice of Transfer of Excess Pension Assets to Retiree Health Benefit or Life Insurance Accounts () 7 Notice of Determination Letter Request () 7 Notice of Request for Waiver of Minimum Funding Standards (/MPPP) Notice of Right to Diversify () 8 Investment Blackout Notice () 13 Section 404(c) Plan Disclosure () 8 Notice of Intent to Terminate Plan () 13 Participant Fee Disclosure () Calendar of Administrative Requirements for Plans with January 1 Plan Years

2 Reporting requirements IRS Form 1099-R Report of distributions of $10 or more from pensions, annuities, retirement or profit sharing plans, IRAs, insurance contracts, etc. Dividends on employer securities that are distributed from an ESOP under IRC section 404(k) must be reported on a Form 1099 R that does not report any other distributions. IRS Form 5558 Application for extension of time to file Form 5500 and Form 8955-SSA. If Form 5558 is filed on time and is complete, the extension of up to 2 ½ months for Form 5500 and/or Form 8955-SSA is automatic. Payees and IRS. IRS January 31 of the year following the year in which distribution made to payees; February 28 (March 31 if filed electronically) to IRS; additional 30 days to file with IRS if extension requested on IRS Form By the last day of the seventh month after the end of the plan year. For a short plan year, by the last day of the seventh month after the short year ends. Form 5500 (including applicable schedules and attachments) IRS Form 8955-SSA Not required if Form 5500 or Form 8955-SSA filer uses automatic extension; i.e., plan year and employer tax year are the same and the employer was granted extension for income tax return. In that case, Form 5500 and Form 8955-SSA filers are automatically granted extensions of time to file until the extended due date of the federal income tax return. Annual return/report of employee benefit plan. DOL Annual statement identifying separated participants with deferred vested benefits. Must be filed electronically using EFAST2. The form was developed jointly by the IRS, DOL and PBGC and the information satisfies annual reporting requirements under ERISA and the IRC. IRS The last day of the seventh month after the end of the plan year. A plan may obtain a one-time extension (up to 2 ½ months) by filing IRS Form 5558 by the last day of the seventh month after the plan year ends. This extension is not needed if the automatic extension described below applies, because the extended due date would be the same. Automatic extension until the extended due date of the federal income tax return of the employer (but not beyond 9 ½ months after the end of the plan year) if the plan year and employer tax year are the same and employer is granted extension for corporate tax return. Same as for Form 5500 above Calendar of Administrative Requirements for Plans with January 1 Plan Years

3 Notice of Qualified Separate Lines of Business (QSLOBs) Plan Merger, Consolidation, or Transfer of Assets or Liabilities Comprehensive PBGC Premium Filing PBGC Reporting for Substantial Underfunding Notice that employer elects to be treated as operating QSLOBs or that it either modifies or revokes a previously filed notice. Actuarial statement and information concerning the merger, spinoff, consolidation or transfer of assets and liabilities. Almost all transactions will be exempt, and certain transactions involving a spinoff of a small part of a plan, or a merger of a small plan into a much bigger plan, will be exempt. A comprehensive premium filing to report flat-rate and variable rate premiums owed and related data. Annual reporting of employer financial and plan actuarial information. Required when any plan in the controlled group has a funding ratio below 80%. The PBGC waives reporting if the aggregate underfunding of the controlled group s underfunded defined benefit plans does not exceed $15 million. Reportable Events Statement of facts related to the reportable event, and plan and actuarial information. Reportable events include, but are not limited to: (i) 20% reduction in active participants since beginning of year or 25% reduction since beginning of previous year; (ii) inability to pay plan benefits when due; (iii) changes in contributing sponsor or plan s controlled group; (iv) insolvency or liquidation of contributing sponsor or controlled group member; (v) failure to make required minimum funding payment; (vi) application for a minimum funding waiver; and (vii) transfer of benefit liabilities outside controlled groups. IRS Form 5310-A used. IRS Form 5310-A used. PBGC Must be filed electronically using My Plan Administration Account (My PAA). PBGC Must be filed electronically using the e-4010 module of PBGC s e-filing Portal. PBGC Form 10 or Form 10-Advance is used. Notice must be given on or before the notification date. The notification date for a calendar year is the later of: (i) October 15 following the calendar year; or (ii) the 15th day of the 10th month after the close of the plan year of the employer s plan that begins earliest in the calendar year. At least 30 days before the merger, consolidation, or transfer of assets or liabilities. The 15th day of the 10th month after the end of the plan year, with earlier or later required dates for certain situations (e.g., terminating plans, new plans, certain plans changing plan years, etc.). Variable-rate premium can be an estimate with later true-up if certain conditions are met. A reconciliation filing must be made by the end of the sixth calendar month that begins on or after the regular premium filing due date (e.g., April 30 for calendar year plans). No later than the 105th day after the close of the filer s information year. If all nonexempt controlled group members have the same fiscal year, the information year is the fiscal year. If non-exempt members of a controlled group have different fiscal years, the information year is the calendar year. Post-event reporting is required within 30 days after plan sponsor knows, or has reason to know, that a reportable event has occurred. Advance reporting (applicable to certain non-public companies) is required no later than 30 days before the effective date of certain reportable events. Waivers are available for some plan sponsors for some reportable events. The PBGC may grant extensions of the time to file on a case-by-case basis Calendar of Administrative Requirements for Plans with January 1 Plan Years

4 Notice of Failure to Make Required Contributions of More than $1 Million Information needed by the PBGC to make decisions regarding enforcement of a lien imposed by ERISA in favor of the plan for failure to make certain required contributions. PBGC Form 200 is used. No later than 10 days after the due date of the required payment. Notice is still required if missed contribution is made within the 10-day period. Substantial Cessation of Operations A substantial cessation of operations occurs if there is a permanent cessation of operations at a facility which results in a workforce reduction of a number of eligible employees at the facility equivalent to more than 15 percent of the number of all eligible employees at all facilities of the employer. Eligible employees are employees eligible to participate in any or plan of the employer. Plans that were 90% or better funded (using liabilities used for PBGC variable premium calculations) in the plan year before the cessation occurred are exempt. PBGC Within 60 days of a cessation of operations that is subject to ERISA section 4062(e). Notice of Withdrawal of a Substantial Employer from a Multiple Employer Plan Notification of withdrawal and request for determination of associated liability. PBGC Within 60 days after withdrawal from plan Calendar of Administrative Requirements for Plans with January 1 Plan Years

5 Disclosure Requirements Annual Funding Notice Summary of plan s funded status, value of plan s assets and liabilities, funding policy and asset allocation, and information about certain plan amendments and other known events having a material effect on funded status. Participants, beneficiaries receiving benefits and labor organizations representing plan participants; PBGC if underfunded by more than $50 million. Not later than 120 days after the end of the plan year. Small plans (100 or fewer participants in the controlled group) have until the Form 5500 is filed (if timely filed). Summary Annual Report (SAR) Summary information on plan s financial activities as reported on Form 5500 Annual Report and statement of right to receive copy of Form 5500 Annual Report. Participants and those beneficiaries receiving benefits. Within nine months after the end of the plan year or, if later, two months after Form 5500 is due (including any extension). Summary of Material Modification (SMM) Description of any material modification to the plan and any change in the information required to be included in the SPD. SMM requirements may be satisfied by distributing updated SPD by the SMM due date. Participants and those beneficiaries receiving benefits. Not later than 210 days after the end of the plan year in which the change is adopted. Summary Plan Description (SPD) Summary of plan provisions and information about how the plan operates. The SPD must be written in a manner calculated to be understood by the average plan participant and must be sufficiently comprehensive to apprise the participants and beneficiaries of their rights and obligations under the plan. Participants and those beneficiaries receiving benefits. New plans within 120 days after becoming subject to ERISA. New participants within 90 days of becoming a participant. New beneficiaries within 90 days after first receiving benefit. Updated SPDs must be furnished every 5 years (within 210 days after the close of the plan year in which the 5-year period ends) if changes were made to SPD information; otherwise must be furnished every 10 years. Periodic Benefit Statement Individual benefit statement showing the value of each investment to which account assets are allocated. Quarterly statements must also include an explanation of any limitations or restrictions on the right to direct an investment; an explanation of the importance of a well balanced and diversified investment portfolio, including a statement of the risk that holding more than 20% of a portfolio in the security of one entity (such as employer securities) may not achieve adequate diversification; and a notice directing the participant or beneficiary to DOL s website for additional information on individual investing and diversification. Participants and beneficiaries. At least once each calendar quarter to participants and beneficiaries who have the right to direct investments, and annually to those who do not. The quarterly statement must be provided within 45 days of the end of the calendar quarter. The deadline for furnishing benefit statements under plans that do not provide for participant directed investments is the timely filing date of the Form 5500 for the plan year to which the statement relates Calendar of Administrative Requirements for Plans with January 1 Plan Years

6 Periodic Benefit Statement Individual statement of accrued and vested pension amounts (or, if not yet vested, the earliest date on which benefits become vested) and an explanation of any permitted disparity or floor offset arrangement applied in determining the participant s accrued benefit. Vested participants who are employed by the employer when the statement is furnished. plans generally are required to furnish participants a pension benefit statement at least once every three years. The plan may satisfy the alternative notice requirement for plans if the administrator provides, at least once a year, notice of the availability of a pension benefit statement and how to obtain it. 401(k)/(m) Safe Harbor Notice Notice of eligible employee s rights and obligations under a 401(k) safe harbor plan. The notice must include details on: the safe harbor matching or nonelective contribution formula that is used, other contributions under the terms of the plan, the plan to which the safe harbor contributions are made (if more than one plan), the type and amount of compensation that may be deferred under the plan, Eligible employees. At least 30 days and no more than 90 days before the beginning of each plan year. For new participants, no more than 90 days before his/her eligibility date and no later than the eligibility date (or if later, date needed to reflect elections for first payroll period for which contributions can be made). Notices delivered outside of the 90/30-day window may satisfy the notice requirement if given within a reasonable period of time before the beginning of the plan year (or the date the employee becomes eligible) based on all facts and circumstances (including lead time required to implement participant elections). how to make cash or deferred elections, the specific time periods available under the plan to make cash or deferred elections, withdrawal and vesting provisions for plan contributions, and how to easily obtain information about the plan (including a copy of the summary plan description). Also, if the employer wishes to retain the ability to amend the plan during the year to reduce or suspend matching or nonelective safe harbor plan contributions (effective no earlier than 30 days after the participant receives a supplemental notice regarding such an amendment), the notice should include a statement that the employer reserves such right Calendar of Administrative Requirements for Plans with January 1 Plan Years

7 Updated 401(k)/(m) Safe Harbor Notice for Mid-Year Changes For any mid-year change that is permitted pursuant to Notice , the sponsor must distribute an updated safe harbor notice that describes the mid-year change and its effective date. The additional notice is not required for changes to information that is not otherwise required to be contained in a safe harbor notice, even if that information is provided in a plan s safe harbor notice. Eligible employees. Within a reasonable period before the change takes effect; deemed satisfied if at least 30 days (and not more than 90 days) before the effective date of the change. If it is not practicable for the notice to be provided before the effective date of the change (e.g., in the case of a mid-year amendment to increase matching contributions retroactively to the beginning of the plan year), it is treated as timely if it is provided as soon as practicable, but not later than 30 days after the date the change is adopted. 401(k)/(m) Safe Harbor Discontinuance Notice Notice of an amendment during a plan year that reduces or suspends safe harbor matching contributions on future elective contributions, nonelective contributions, and, if applicable, employee contributions. Eligible employees. At least 30 days prior to the effective date of the plan amendment. Automatic Contribution Arrangement Notice (QACA/EACA) Notice of the participant s rights and obligations under a plan s automatic contribution arrangement. The notice must describe: the amount of elective deferrals that will be made on the participant s behalf in the absence of an affirmative election, the participant s right not to have elective deferrals made on his/her behalf, or to elect to have such deferrals made at a different percentage or amount. an explanation of how the contributions will be invested in the absence of any investment election by the participant. Notice of an eligible automatic contribution arrangement (EACA) must also include notice of the employee s rights to make a permissible withdrawal, if applicable, and the procedures to elect such a withdrawal. Eligible employees. Notice of a plan s automatic contribution arrangement may be combined with notice of the plan s QDIA. A sample notice (Sample Automatic Enrollment and Default Investment Notice) is available at irs.gov/pub/irs-tege/ sample_notice.pdf and may be used to satisfy both of these notice requirements. Generally, at least 30 days and no more than 90 days before the beginning of each plan year. Initial notice to newly eligible employee required no later than first individual deferral. If it is not practical to give advance notice (e.g., because the employee is eligible immediately upon hire), notice may be given before the first pay date for the payroll period that includes the employee s eligibility date. If the ACA is intended to be a qualified automatic contribution arrangement (QACA), this notice must be provided in addition to (and may be combined with) the 401(k)/(m) safe harbor plan notice Calendar of Administrative Requirements for Plans with January 1 Plan Years

8 Notice of Qualified Default Investment Alternative (QDIA) Initial notice must include: a description of the circumstances under which assets may be invested on behalf of the participant or beneficiary in a QDIA; an explanation of the right to direct the investment of assets in their individual accounts; an explanation of the QDIA, including the investment objectives, risk and return characteristics (if applicable), and fees and expenses attendant to the investment alternative; a description of the right to direct the investment of assets in a QDIA to any other investment alternative, including a description of any applicable restrictions, fees or expenses in connection with the transfer; and an explanation of where to obtain information about alternative investments. Participants and beneficiaries who are eligible to make investment elections under the plan. Notice of a plan s QDIA may be combined with notice of the plan s automatic contribution arrangement. A sample notice (Sample Automatic Enrollment and Default Investment Notice) is available at irs.gov/pub/irs-tege/ sample_notice.pdf and may be used to satisfy both of these notices requirements. Initial notice: (i) at least 30 days in advance of the date of plan eligibility, or any first investment in a QDIA on behalf of the participant or beneficiary; or (ii) on or before the date of plan eligibility, provided the participant has the opportunity to make a permissible withdrawal under an eligible automatic contribution arrangement. Annual notice at least 30 days before the beginning of the plan year. Notice of Qualified Change in Investment Options (QCIO) Notice of change in investment options, including information comparing the existing and new options, and an explanation stating that, in the absence of affirmative investment instructions to the contrary, the participant s or beneficiary s account will be invested according to the reallocation described as part of the QCIO. Participants and beneficiaries who are eligible to make investment elections under the plan. Not more than 60 days, but at least 30 days, before the effective date of the QCIO Calendar of Administrative Requirements for Plans with January 1 Plan Years

9 Notice of Right to Diversify Notice of right to diversify investments in employer stock, statement of the importance of diversifying retirement account assets and plan contact information. Right to diversity applies immediately with respect to employer securities attributable to elective deferrals, after-tax employee contributions and rollover contributions. Only participants with three years of vesting service (and their alternate payees), and beneficiaries of deceased participants, have to be given the right to diversify employer securities attributable to employer contributions (e.g., matching contributions or profit sharing contributions). Participants, alternate payees and beneficiaries. IRS Notice includes a model notice. Not later than 30 days before the first date on which the individual is eligible to exercise diversification rights. Section 404(c) Plan Disclosure Investment related and certain other disclosures for participant-directed individual account plans. Disclosure that the plan intends to comply with section 404(c) of ERISA and certain additional disclosures if the plan offers company stock as an investment option. Participants and beneficiaries. Before investment instructions are to be given and upon request. Participant Fee Disclosure Calendar of Administrative Requirements for Plans with January 1 Plan Years General plan information, administrative expense information and individual expense information in participant-directed individual account plans. Also, investment-related information such as fund identification information, performance data, benchmark data, fee and expense information, Internet website address for additional information and a glossary of terms. In addition to the plan-related information that must be furnished up front and annually, participants must receive statements, at least quarterly, showing the dollar amount of the plan-related fees and expenses (whether administrative or individual ) actually charged to or deducted from their individual accounts, along with a description of the services for which the charge or deduction was made. These specific disclosures may be included in quarterly benefit statements required under section 105 of ERISA. Participants and beneficiaries On or before the date a participant or beneficiary can first direct investments and at least annually thereafter. At least once annually thereafter means at least once in any 14-month period without regard to whether the plan operates on a calendar year or fiscal-year basis.

10 Individual Deferred Vested Pension Statement Name of the plan, name and address of the plan administrator, name of the participant, and nature, amount and form of the deferred vested benefit to which such participant is entitled. Terminated participants with deferred vested benefits. ERISA section 209 may require plan sponsors to provide similar statements to terminated non-vested participants. Such statements would have the same information as is provided in Periodic Benefit Statements see above. Same as for Form 5500 above. Notice of Receipt of Domestic Relations Order Notification of receipt of domestic relations order and the plan procedures for determining the qualified status of the order. Notification is also required when the qualified status of the order is determined. Participant and alternate payee(s). Participants and alternate payee(s) are to be notified promptly upon receipt of the domestic relations order (including the plan s procedures for determining the qualified status of the order). Notice of the determination of the order s qualified status must be given within a reasonable period after the order is received. Notice of Suspension of Benefits Explanation of why benefit payments are being suspended upon reemployment or continued employment after reaching normal retirement age, description of plan provisions relating to suspension of payment, and claim procedure for affording a review of the suspension of benefits. Participants who commenced receiving benefit payments that are suspended because of reemployment, or whose benefit payments are suspended because of continued employment after normal retirement age. During first calendar month or payroll period in which the plan suspends benefits on account of reemployment or continued employment beyond normal retirement age. Notice of Significant Reduction in Rate of Future Benefit Accrual / MPPP Notice of plan amendment providing for a significant reduction in the rate of future benefit accruals (including a plan freeze), or the elimination or significant reduction in an early retirement benefit or retirement-type subsidy. If a plan amendment offers a choice between a new benefit formula and an old benefit formula, the notice must provide information sufficient to enable an informed choice. Participants and alternate payees whose rate of future benefit accrual is reasonably expected to be significantly reduced by the amendment. Also, notice must be provided to any contributing employer, and to any employee organization representing employees. Generally, at least 45 days before the effective date of the plan amendment. The 45-day advance notice period is shortened to 15 days for amendments adopted in connection with business transactions and for amendments of small plans. If an amendment is adopted in connection with an acquisition or disposition involving the transfer of plan liabilities, and the amendment affects only early retirement benefits or retirement-type subsidies, then notice must be provided no later than 30 days after the effective date of the amendment Calendar of Administrative Requirements for Plans with January 1 Plan Years

11 Rollover Notice Notice of the right to elect a direct rollover and that automatic distribution by direct rollover applies to certain distributions; the required withholding of tax on eligible rollover distributions not rolled over; the differences between rollover contributions to traditional IRAs and qualified rollover contributions to Roth IRAs; the taxpayer eligibility requirements that apply to qualified rollover contributions to Roth IRAs; and the related tax and withholding consequences of each, as well as certain other tax rules. A 402(f) notice is not required for a participant making an in-plan Roth rollover of a nondistributable amount. Explanation of Qualified Preretirement Survivor Benefit / MPPP A general explanation of the qualified preretirement survivor annuity (QPSA), the circumstances under which it would be paid, the availability of optional forms of payment and a description of the financial effect of electing the QPSA on the participant s benefit (i.e., an estimate of the reduction to the participant s estimated normal retirement benefit). Participants, alternate payees and beneficiaries who are eligible to receive distributions that are eligible rollover distributions. Participants At least 30 days and no more than 180 days before distribution is made. However, the distributee may waive the 30-day period provided the plan administrator clearly informs the distributee of his/her right to consider whether or not to elect a direct rollover for at least 30 days. During the period from the beginning of the plan year in which the employee attains age 32 to the end of the plan year in which the employee reaches age 34. Special rules apply for participants who commence participation after 35 or who separate from service prior to 35. Not required if plan fully subsidizes QPSA and doesn t allow a participant to waive it or to select a non-spouse beneficiary. Explanation of Qualified Joint and Survivor Annuity (QJSA); Financial Effect and Relative Values of Optional Forms of Payment / MPPP Terms and conditions of joint and survivor annuity, right to waive, right to revoke waiver, spousal consent conditions, financial effect and relative values of optional forms of payment. Participants No less than 30 days and no more than 180 days before the annuity starting date. Alternatively, no less than seven days before distribution date if certain conditions are satisfied. The QJSA notice must be provided before the annuity starting date, except that a plan may provide for a retroactive annuity starting date Calendar of Administrative Requirements for Plans with January 1 Plan Years

12 Notice of Right to Defer a Distribution and Notice of Consequences of Failing to Defer Based on IRS Notice , the right to defer notice would generally include the following: (i) for a plan, information on how much larger benefits will be if the distribution is deferred; and (ii) for a plan, the investment options available (including fees) if distributions are deferred. Notice also requires plans to identify the portion of the SPD containing any special rules that might materially affect a participant s decision to defer (if any such special rules exist). IRS proposed regulations require the notices to include, among other things, (i) a description of the federal tax implications of failing to defer; and (ii) information on any plan provisions (of this plan or another plan) that could reasonably be expected to materially affect a participant s decision to defer receipt (e.g., a provision under which a participant who fails to defer may lose retiree health coverage). Plan sponsors unable or unwilling to conform their explanations to either the proposed regulations or Notice s safe harbor, may rely on any other reasonable attempt to satisfy the disclosure mandates until final regulations are issued. Participants No less than 30 days and no more than 180 days before the annuity starting date. Notice of Failure to Meet Minimum Funding Standards Notice of failure to make an installment payment to meet the minimum funding standard within 60 days following the due date for such payment. Participants, beneficiaries and alternate payees. Notice to be made within a reasonable period of time after the failure. Notice is not required if a funding waiver is requested in a timely manner; if waiver is denied, notice must be provided within 60 days after the denial. Notice of Funding- Based Limitations on Plan Distributions Written notice of: (i) funding-based distribution limitations on shutdown benefits and other unpredictable contingent-event benefits; (ii) funding-based limitations on accelerated benefit distributions; and/or (iii) limitations on benefit accruals for plans with certain funding shortfalls. Participants and beneficiaries who could be affected by the restriction. Generally within 30 days after funding based restrictions take effect Calendar of Administrative Requirements for Plans with January 1 Plan Years

13 Notice of Transfer of Excess Pension Assets to Retiree Health Benefit or Life Insurance Accounts Plan and financial information concerning transfer of excess pension assets to retiree health benefit accounts and applicable life insurance accounts. Sponsor of transferring pension plan provides notice to DOL, IRS, plan administrator and employee organizations representing plan participants. Plan administrator provides notice to participants and beneficiaries of plan transferring assets, including the participant s nonforfeitable benefit. No later than 60 days before date of transfer. Notice of Determination Letter Request Relevant information concerning plan requesting determination letter and rights of interested parties to comment on plan. Generally, all current employees eligible to participate in plan and collective bargaining representatives of present employees. In a terminating plan, present employees with accrued benefits, former employees with vested benefits and beneficiaries of deceased former employees currently receiving benefits. Not less than 10 days nor more than 24 days prior to the date the application for a determination is made. Effective January 1, 2017, the scope of the determination letter program for individually designed plans was limited to initial plan qualification, qualification upon plan termination, and certain other circumstances. Notice of Request for Waiver of Minimum Funding Standards / MPPP The notice must contain certain information such as: (i) the plan year for which the waiver is being requested; (ii) the present value of vested benefits under the plan; (iii) the present value of benefits, calculated as though the plan terminated; (iv) the fair market value of plan assets; and (v) the interest rate used in calculating the present values. Participants, beneficiaries, alternate payees and employee organizations representing employees covered by the application. Within 14 days prior to the date of application Calendar of Administrative Requirements for Plans with January 1 Plan Years

14 Investment Blackout Notice Notification of any period of more than 3 consecutive business days when there is a temporary suspension, limitation or restriction under an individual account plan on directing or diversifying plan assets, obtaining loans, or obtaining distributions. Participants and beneficiaries whose rights under the plan will be temporarily restricted and issuers of employer securities subject to the blackout period. Generally, not more than 60 days and not less than 30 days before commencement of the blackout period. DOL Reg provides a model notice. Notice of Intent to Terminate Plan () Advises of proposed termination and provides information about the termination process, possible annuity providers, etc. Participants, beneficiaries, alternate payees, and employee organizations representing plan participants. At least 60 days and no more than 90 days before the proposed termination date. Notice of insurers that may be selected may be provided in a supplemental notice no later than 45 days before the date of distribution Calendar of Administrative Requirements for Plans with January 1 Plan Years

15 2019 calendar of administrative requirements for plans with January 1 plan years Month Due Date Plan Type Done Item January 15-Jan Payment of fourth quarterly contribution due for 2018 plan year, if applicable 31-Jan Form 1099-R due to payees for distributions processed in Jan Form W-2 for 2018 February 14-Feb Quarterly periodic benefit statement for participant-directed account plans for fourth quarter of the 2018 plan year 28-Feb April 1-Apr Paper filing of Form 1099-R due to IRS. Later due date if filing electronically (generally must file electronically if at least 250 information returns) Initial minimum distributions to commence for participants who have reached their required beginning date (i.e., following the calendar year in which the later of age 70½ or retirement occurs) 1-Apr Electronic filing of Form 1099-R due to IRS (generally must file electronically if at least 250 information returns) 15-Apr Payment of first quarterly contribution due for 2019 plan year, if applicable 30-Apr May 1-May Annual funding notice (for plans with more than 100 participants on any day during the plan year determined by aggregating all plans of the controlled group) Notice of funding-based limitation on certain forms of distribution if the presumed AFTAP drops below 60% or 80% at April 1 and benefit restrictions apply; otherwise 30 days after an AFTAP of less than 60% or 80% is certified (or deemed certified), benefit restrictions apply, and notice of the applicable restrictions was not previously provided 15-May Quarterly periodic benefit statement for participant-directed account plans for first quarter of the 2019 plan year July 15-Jul Payment of second quarterly contribution due for the 2019 plan year, if applicable 29-Jul Summary of any material modifications (SMM) adopted in Jul 31-Jul 31-Jul 31-Jul 2018 Forms 5500 and 8955-SSA must be filed. Extension available by filing Form 5558 or if plan and tax years are the same and sponsor has a corporate tax filing extension Notice to terminated vested employees reported on the 2018 Form 8955-SSA. Extension available as described above for Form 5500 Annual funding notice for 2018 plan year (for plans with 100 or fewer participants on each day of the 2018 plan year in all plans of the controlled group). Extension available as described above for Form 5500 Annual periodic benefit statement for non-participant-directed account plans due for 2018 plan year. Extension available as described above for Form 5500 August 14-Aug Quarterly periodic benefit statement for participant-directed account plans for second quarter of the 2019 plan year Calendar of Administrative Requirements for Plans with January 1 Plan Years

16 Month Due Date Plan Type Done Item September 13-Sep Payment of any remaining 2018 plan year contributions must be made, if applicable 30-Sep 2018 summary annual report (SAR) due. Extension available in certain cases October 15-Oct Payment of third quarterly contribution due for the 2019 plan year, if applicable 15-Oct 2018 comprehensive premium filing due to PBGC 15-Oct 15-Oct Extended due date for 2018 Forms 5500 and 8955-SSA and notice to terminated vested employees, if relying on extension Extended due date for annual funding notice for 2018 plan year (for plans with 100 or fewer participants in the controlled group on each day of the plan year) 15-Oct Extended due date for 2018 annual periodic benefit statement for non-participant-directed account plans 31-Oct Notice of funding-based limitation on certain forms of distribution and on benefit accruals if the deemed AFTAP is less than 60% because no AFTAP was certified by 9/30 November 14-Nov Quarterly periodic benefit statement for participant-directed account plans for the third quarter of the 2019 plan year December 2-Dec 401(k)/401(m) safe harbor notice furnished at least 30 days but no more than 90 days before the beginning of the plan year 2-Dec Notice of qualified default investments furnished at least 30 days before the beginning of each plan year 2-Dec 13-Dec Extended due date for 2018 SAR Notice of automatic contribution arrangement furnished at least 30 days but no more than 90 days before the beginning of the plan year 31-Dec Annual benefit statement alternative notice requirement explaining the availability of a benefit statement and how to obtain The IRS, DOL, PBGC and SEC, as applicable, extend the filing due date to the following business day when the due date falls on a weekend or holiday. However, this extension does not apply for purposes of disclosures, contributions or distributions. About Willis Towers Watson Willis Towers Watson (NASDAQ: WLTW) is a leading global advisory, broking and solutions company that helps clients around the world turn risk into a path for growth. With roots dating to 1828, Willis Towers Watson has over 40,000 employees serving more than 140 countries. We design and deliver solutions that manage risk, optimize benefits, cultivate talent, and expand the power of capital to protect and strengthen institutions and individuals. Our unique perspective allows us to see the critical intersections between talent, assets and ideas the dynamic formula that drives business performance. Together, we unlock potential. Learn more at willistowerswatson.com. Copyright 2019 Willis Towers Watson. All rights reserved. WTW-NA-2019-WTW willistowerswatson.com