PLAN SPONSOR NEWSLETTER

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1 Benefits in Focus January 2019 PLAN SPONSOR NEWSLETTER Retirement Compliance Calendar Retirement plan sponsors are responsible for compliance with many ongoing reporting, disclosure and notice requirements. This Retirement Compliance Calendar summarizes the major requirements that apply to Defined Benefit ( ) and Defined Contribution ( ) plans for Due dates are based on a calendar year plan year and are applicable to plans subject to the Employee Retirement Income Security Act of 1974 ( ERISA ). Please contact your USI Consulting Group representative if you have questions regarding these requirements and their application to your plan(s). January / Review 2019 Limits / Make Fourth Quarter Contribution for 2018 Provide IRS Form 1099-R February / Submit IRS Form 1099-R Adhere to IRS dollar limitations on benefits and contributions. Quarterly contribution due 15 days after the end of applicable quarter. Send Form 1099-R to participants who received distributions and/or deemed distributions in the previous year. File Form 1099-R with IRS to report distributions and/or deemed distributions made in 2018, if not filing electronically. January 1 - January 15 January 31 February 28 Benefits in Focus is a publication circulated by the USI Consulting Group Regulatory & Compliance Department and is designed to highlight various retirement and employee benefit matters of general interest to our readers. It is not intended to interpret laws, regulations or to address specific client situations. The information contained herein is meant for general educational purposes only. March Make Corrective Distributions for Excess 2018 / Apply for Waiver for Minimum Funding Standard Obtain AFTAP Certification to Avoid Presumption Deadline for processing corrective distributions for failed Actual Deferral Percentage (ADP) and Actual Contribution Percentage (ACP) tests to avoid a 10% excise tax. Application for Waiver for Minimum Funding Standard due for and money purchase plans, where applicable. Deadline for plan actuary to certify Adjusted Funding Target Attainment Percentage (AFTAP) in order to avoid presumption that the current year AFTAP is to be the prior year AFTAP minus 10% (assuming benefit limits did not apply in the prior year). March 15 March 15 (Due no later than the 15th day of the 3rd month after the close of the plan year for which the waiver is requested) March 31 Page 1 of 5

2 Page 2 of 5 April / Make Initial Required Minimum Distributions for 2018 Required beginning date for participants attaining age 70½ or retiring after age 70½ in prior year for taking first required minimum distribution (RMD) under IRC Section 401(a)(9) for / Submit IRS Form 1099-R Deadline for electronic filing of Form 1099-R for prior year distributions and/or deemed distributions. / / File Corporate Tax Return and Deposit Employer Request Automatic Extension for Corporate Tax Returns to Make First Quarter Contribution for 2019 Distribute Excess Deferrals (402(g) Refunds) Deadline to file Form 1120 unless requesting an extension of time to file. Prior year employer matching and profit sharing contributions due for plan corporate entities in order to take tax deduction. April 1 April 2 (For plans with a tax year ending December 31, without corporate tax extension) Deadline to file Form Deadline for corrective distributions of 2018 deferrals in excess of $18,500. Deposit Employer 2018 employer matching and profit sharing contributions due for unincorporated entities in order to take tax deduction. (For plans with a tax year ending December 31, without tax extension) File PBGC 4010 Deadline for filing PBGC (For plans with a calendar year = fiscal year) Distribute Annual Funding Annual funding notice to participants, beneficiaries, and labor organizations representing participants from plan sponsors of single and multiemployer pension plans with more than 100 participants. April 30 (Due within 120 days after the close of the plan year) Distribute of Benefit Limitations and Restrictions to participants of limitations on benefit increases, benefit payments and benefit accruals that apply if a plan s AFTAP is less than specific percentages. April 30 (Or 30 days after certain specified dates to which the benefit restriction applies) June EACA s Make Corrective Distributions for Certain Excess 2018 and Excess Aggregate Deadline for processing corrective distributions for failed ADP/ACP test from a plan with an Eligible Automatic Contribution Arrangement (EACA) that covers all eligible employees to avoid a 10% excise tax. June 30 July Make Second Quarter Contribution for 2019 July 15 / Distribute Summary of Material Modifications to Update SPDs for 2018 Amendments Summary of Material Modifications due to participants (due no later than 210 days after the end of the plan year in which the plan change is adopted.) July 29

3 Page 3 of 5 July / Submit Form 5500 Form 5500 due (due seven months after plan year ending, unless extension applies). July 31** Submit Form 5558 Submit Form 8955-SSA Form 5558 Application for Extension of Time to File Certain Employee Returns (Form 5500, 5330) due on or before normal due date for filing Form 5500 and/or Form Form 8955-SSA - report certain information relating to each participant with a deferred vested benefit. Submit Form 5330 September Make various Credit Balance elections for 2018 and/or 2019 s. / / Minimum Required Distribute Summary Annual Report (SAR) Form 5330 excise taxes related to employee benefit plans due to IRS (e.g., excise taxes for late test corrections, late deposits of employee deferrals) unless extension applies. Deadline to add excess contributions for the 2018 to the January 1, 2019 Prefunding Balance and/or use Credit Balance for the 2018 contribution requirement. Deadline to make minimum required contributions for money purchase pension, target benefit and plans. Deadline for plans with plan year ending to provide SAR to participants and participants for plans not subject to the Annual Funding Requirement. Final AFTAP Certification actuary makes final certification for current plan year. October / File Corporate Tax Return and Deposit Employer Make Third Quarter Contribution for 2019 Distribute Annual Funding File 2019 PBGC Comprehensive Filing Extended deadline to file Form Extended deadline to deposit tax deductible contributions for qualified plans for those sponsors that filed a corporate tax extension. Deadline for small plans (covering 100 or fewer participants) to distribute Annual Funding. Annual PBGC Premium Payment for plans of all sizes, which includes the variable-rate premium and flat-rate premium. / File IRS Form 5310-A To give notice to IRS of Qualified Separate Lines of Business, where applicable. September 15 September 15 September 30 (9 months after yearend or 2 months after filing Form 5500) September 30 (If a Range Certification was issued, the deadline is extended until ) (Deadline in order to deduct contributions for 2018 plan year) (Or the date Form 5500 is filed, if earlier) (9 1/2 months after end of plan year) ** / Submit Form 5500 and Form 8955-SSA Deadline to submit Form 5500 and Form SSA for plans with Form 5558 filing extension. ** (2½ month extension if Form 5558 was filed timely) Amend the plan to correct for coverage/ nondiscrimination failure Deadline for adopting retroactive amendment to correct coverage/nondiscrimination failure

4 Page 4 of 5 October December Distribute Annual 401(k) Safe Harbor Distribute Qualified Default Investment Alternative (QDIA) Provide notice to eligible employees. Employers who want the ability to provide a Qualified Non-Elective Contribution (QNEC) 3% employer contribution must issue a 401(k) Safe Harbor Contingent notice to eligible employees. Provide annual notice to all participants (including alternate payees and beneficiaries) to inform of their rights to direct investments and how their accounts will be invested if they do not direct investments. Distribute Annual Automatic Enrollment 403(b) Annual Contribution December / Make 2019 Required Minimum Distributions Age 70½ / Adopt Discretionary Amendments Provide annual notice to all eligible employees (can be combined with QDIA notice). Provide annual notice to all eligible employees. October 1 - (no more than 90 days 2020 plan year Due to participants who have begun receiving minimum distributions. Deadline for formal adoption of amendments for any discretionary changes that became effective during the plan year. Annual Benefit Statement As an alternative to furnishing a Benefit Statement once every three years, provide an annual notice to participants regarding availability and how to obtain Benefit Statements. Benefit Statement requirement considered met if notice is provided at least once per year Review the Forfeiture Account Allocate Forfeiture accounts. Review the plan document regarding the allocation of Forfeiture monies. Last day of Make Corrective Distributions for Excess 2018 Deadline for distribution of corrective distributions (for failed ADP/ACP test with 10% excise tax). Credit Balance Elections Deadline for plan sponsor to make a voluntary election to reduce credit balances, or revoke a previous credit balance election, for funding purposes. Final AFTAP Certification Deadline for plan actuary to certify final AFTAP if plan is operating under an issued range certification. Intranet posting of Annual Form 5500 and Schedule SB Sponsors post certain information about their Defined Benefit on their intranet websites. (recommended)

5 Page 5 of 5 December 2019 March 2020 April (b) s Required Amendments List ( ) 403(b) Document Restatement Document Restatement Initial Participant Fee Annual Participant Fee Quarterly Participant Fee of any change in fees Document Compliance Deadlines for 2019, 2020 and Amend for final regulations for cash balance/ hybrid plans. - Amend for benefit restrictions applicable to eligible cooperative plans or eligible charity plans. - Amend for final regulations for partial annuity distribution options (if applicable). New pre-approved 403(b) plan document has been issued by the IRS. Sponsors have until March 31, 2020 to restate plan documents. Sponsors of a pre-approved plan document (i.e. prototype plan) have until April 30, 2020 to restate plan documents. General - Participant Fee s (ERISA Section 404a-5) Provide initial fee disclosure to newly eligible participants. Provide annual fee disclosure to active participants. Provide quarterly fee disclosure to participants. Provide disclosure of any change in fees to participants (as required)., 2019 March 31, 2020 April 30, 2020 On or before the date the participant can first direct their investments Annual notice is required to be provided to participants within 14 months of the prior year notice At least quarterly (every calendar quarter) At least 30 days, but no more than 90 days prior to the effective date of the change * Dates shown assume a January 1 plan year and calendar year tax years. ** IRS deadline extended to the next business day if due date falls on weekend or legal holiday (Internal Revenue Code Section 7503). This Update has been prepared for informational purposes only and is not designed to be a comprehensive analysis of any topic discussed herein and should not be relied upon as the only source of information. Additionally, this Update is not intended to represent advice or a recommendation specific to your plan. Neither USI nor its affiliates and/or employees/agents offer legal or tax advice. Prior to acting on this information, we recommend that you seek independent advice specific to your situation from a qualified legal/tax professional. For Sponsor use only. Not for use with participants USI Consulting Group. All rights reserved. USI Consulting Group 95 Glastonbury Boulevard, Suite 102 Glastonbury, CT