Cafeteria Plan Discrimination Tests Annual Dollar limits

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1 Employee Benefit Systems, Inc.

Document Restatement Dates Remedial Amendments EGTRRA: Prototype and Volume Submitter DB Documents: April 30, 2012 Summary of amendments since GUST: PPA: Prototype and Volume Submitter DC Documents:

htm#amendments Prototype and Volume Submitter DB Documents: April 30, 2018 Individually Designed Plan Documents (both DB and DC) based on last digit of employer s EIN: Cycle A: 1 or 6 = 1/31/12 Cycle

2 Document Restatement Dates Remedial Amendments EGTRRA: Prototype and Volume Submitter DB Documents: April 30, 2012 Summary of amendments since GUST: PPA: Prototype and Volume Submitter DC Documents: April 30, Prototype and Volume Submitter DB Documents: April 30, 2018 Individually Designed Plan Documents (both DB and DC) based on last digit of employer s EIN: Cycle A: 1 or 6 = 1/31/12 Cycle B: 2 or 7 = 1/31/13 Cycle C: 3 or 8 = 1/31/14 Cycle D: 4 or 9 = 1/31/15 Cycle E: 5 or 0 = 1/31/16 Cafeteria Plan Discrimination Tests 2012 Annual Dollar limits 125 General Eligibility Test: All employees are eligible (no exclusions). 25% Dependent Care Test: Concentration Test no more than 25% of DCAP benefits are provided to HCEs. 25% Nondiscrimination Test: Concentration Test no more than 25% of non-taxable benefits are provided to Key Employees. 55% Average Benefit Test: Average DCAP benefits received by NHCEs are at least 55% of the average benefits received by HCEs. MFSA Test: 70% test, 70%/80% test, fair cross-section test. Note: Application of tests vary according to plan and census specifics; contact DATAIR support if you are unsure. Pension & Benefits Reference Library ASPPA: The ERISA Outline Book, by Sal M. Tripodi (print and online); contact (703) CCH: Pension Plan Guide, (print, CD and online); contact (800) RIA: Pension and Benefits Advisor on Checkpoint (online); contact (800) Aspen Publishers: 5500 Preparers Manual (print), by Janice Wegesin; contact (800) EBIA: Cafeteria Plans Manual (print); contact (866) BenefitsLink: Newsletter (Retirement and Health & Welfare editions) ( ) free; contact Credentialed Education Programs ASPPA: Qualified Plan Financial Consultant (QPFC), Qualified 401(k) Administrator (QKA), Qualified Pension Administrator (QPA), Certified Pension Consultant (CPC) NIPA: Accredited Pension Administrator (APA), Accredited Pension Representative (APR), Distribution Administrator Certificate SOA: Associate of the Society of Actuaries (ASA), Fellow of the Society of Actuaries (FSA), Chartered Enterprise Risk Analyst (CERA) Joint Board: Enrolled Actuary (EA) IRS: Enrolled Agent (EA) ECFC: Certified in Flexible Compensation (CFC) IFEBP: Certified Employee Benefit Specialist (CEBS) DATAIR s Support Announcements & Discussion Forums Use these steps to receive notices of software updates and webinars, and to chat with other DATAIR users: 1. Go to 2. If you already have a Forums account go to step 7; otherwise, click Register Here. 3. Click Agree. 4. Complete at least items with red asterisks and click Submit (store your user name and password in a safe place!) 5. Receive from forums@datair.com and click on the second link (or cut & paste the link into your browser). 6. Click Back to Forum on page announcing that your registration is completed. 7. Enter user name and password, then log in. 8. Click the right-most icon on the first row. You will receive a pop-up notification that you are now subscribed. You may also subscribe to any of the other Forums (rows) that are of interest.

3 1/17/12: PYE 3/31/11 extended 1/31/12: PYE 6/30/11 January 2012 Federal Bank Holidays and DATAIR closings are in black. Compliance dates are in blue. dates are in red. Note that compliance dates are based on calendar plan years except as noted. 1 NEW YEAR S DAY ERISA 404(a) rules effective 2 DATAIR closed ASPPA L.A. Benefits (Los Angeles CA) 12 ASPPA L.A. Benefits (Los Angeles CA) 13 ASPPA L.A. Benefits (Los Angeles CA) Quarterly DB contributions 16 DR. MARTIN LUTHER KING, JR. DAY & pre-4/1/ SSA forms Cycle A submission (PPA IDPs). 1099Rs to employees & beneficiaries. Form 945, if Payment due.

4 2/15/12: PYE 4/30/11 extended 2/29/12: PYE 7/31/11 February NTSAA Advisors Summit (Las Vegas NV) 9 NTSAA Advisors Summit (Las Vegas NV) 10 NTSAA Advisors Summit (Las Vegas NV) Form 945, if no payment due VALENTINE S DAY PRESIDENTS DAY R and 1096 IRS Paper Filing due PBGC estimated Premium: Form 1-ES

5 3/15/12: PYE 5/31/11 extended March Notification of Excess Deferral (for more than one unrelated 401(k)) DAYLIGHT SAVINGS TIME BEGINS Return Excess Contribution to HCEs. End of 2½ month Grace Period ( 125). Corporate tax filing or extension. Application for Waiver of Minimum Funding. 18 ASPPA 401(k) Summit (New Orleans LA) 19 ASPPA 401(k) Summit (New Orleans LA) 20 ASPPA 401(k) Summit (New Orleans LA) SPRING BEGINS 25 Enrolled Actuaries 26 Enrolled Actuaries 27 Enrolled Actuaries 28 EA ECFC Annual 29 ECFC Annual 30 ECFC Annual SPDs for 1/1 entry participants 31 Excise tax: late 2010 ADP/ACP correction. PPA AFTAP Certification due.

6 4/02/12: PYE 8/31/11 4/16/12: PYE 6/30/11 extended 4/30/12: PYE 9/30/11 April End of 90-day runout period ( 125). Service Provider Fee Disclosure deadline. 401(a)(9) RMD (70½) Initial payment R electronic filing DATAIR closed at 12:00 p.m. 7 PASSOVER 8 EASTER TAX DAY! Quarterly DB contributions. Return 402(g) Excess Deferrals. Tax filing or extension for Individuals, Sole Proprietors, and Partnerships Annual Statement of Pooled Fund, other data needed for 5500 & Annual Notice for large & mid-sized DB plans (120 days after pye) PBGC premium due for small DB plans April 29 May 2: NIPA Annual Forum & Expo (Las Vegas)

7 5/15/12: PYE 7/31/11 extended 5/31/12: PYE 10/31/11 May NTSAA 403(b) Compliance April 29 May 2: NIPA Annual Forum & Expo (Las Vegas NV) (Las Vegas NV) 4 NTSAA 403(b) Compliance (Las Vegas NV) Benefits of the South (Atlanta GA) 18 Benefits of the South (Atlanta GA) Mid-Atlantic Benefits (Philadelphia PA) 22 Mid-Atlantic Benefits (Philadelphia PA) MEMORIAL DAY DATAIR closed st annual disclosures to participants due

8 6/15/12: PYE 8/31/11 extended 6/30/12: PYE 11/30/11 June ACOPA Advanced Actuarial (Boston MA) 5 ACOPA Advanced Actuarial (Boston MA) 6 7 ERPA 8 ERPA ASPPA Women s Business Leaders Forum (Charlotte NC) 15 ASPPA Women s Business Leaders Forum (Charlotte NC) SUMMER BEGINS 21 ASPPA Great Lakes Benefits (Chicago IL) 22 ASPPA Great Lakes Benefits (Chicago IL) SHRM Annual & Exposition (Atlanta GA) 25 SHRM Annual & Exposition (Atlanta GA) 26 SHRM Annual & Exposition (Atlanta GA) 27 SHRM Annual & Exposition (Atlanta GA) Deadline for corrective distributions for failed ADP/ACP test without 10% penalty for EACA

9 7/16/12: PYE 9/30/11 extended 7/31/12: PYE 12/31/11 July INDEPENDENCE DAY DATAIR closed ASPPA s Northeast Area Benefits (Boston MA) 10 ASPPA s Northeast Area Benefits (New York NY) ASPPA Western Benefits (Seattle WA) 16 ASPPA Western Benefits (Seattle WA) 17 ASPPA Western Benefits (Seattle WA) 18 ASPPA Western Benefits (Seattle WA) 19 Quarterly DB Contributions 20 RAMADAN Deadline for sending SMM (210th day after PYE after adoption of amendment) 29 Annual Funding Notice due for small DB plans Excise Tax due for prohibited transactions (Form 5330). Statement of Deferred Benefits. Annual Funding Notice for small DB plans (due by earlier of 5500 filing date or deadline with extension).

10 8/15/12: PYE 10/31/11 extended 8/31/12: PYE 1/31/12 August ACOPA Actuarial Symposium (Chicago IL) 11 ACOPA Actuarial Symposium (Chicago IL) st quarterly disclosures to participants due 15 ECFC Administrators Flex Symposium (Chicago IL) 16 ECFC Administrators Flex Symposium (Chicago IL) EID AL FITR

11 9/17/12: PYE 11/30/11 extended September SAR distributed (if 5500 not extended). Final deadline: PPA AFTAP Certification. Notice for PBGC DB plans to waive audit (if 5500 not extended) LABOR DAY DATAIR closed Benefits Forum & Expo/Employee Benefit Adviser Summit (Phoenix AZ) 10 Benefits Forum & Expo/Employee Benefit Adviser Summit (Phoenix AZ) 11 Benefits Forum & Expo/Employee Benefit Adviser Summit (Phoenix AZ) Minimum Funding Contribution Form 5500, if on corporate extension AUTUMN BEGINS ROSH HASHANAH YOM KIPPUR [see top of page]

12 10/1/12: PYE 2/29/12 10/15/12: PYE 12/31/11 extended 10/31/12: PYE 3/31/12 October COLUMBUS DAY Final DC contributions (non-corporations). Quarterly DB contributions (b) failure amendment PBGC premiums: flat and variable rate for mid-sized plans; variable for large plans EID Al ADHA ASPPA Annual 29 ASPPA Annual 30 ASPPA Annual 31 ASPPA Annual

13 11/15/12: PYE 1/31/12 extended 11/30/12: PYE 4/30/12 November Simple Plan Notice 3 4 DAYLIGHT SAVING TIME ENDS 5 6 ELECTION DAY 7 8 ASPPA Cincinnati Pension (Covington KY) 9 ASPPA Cincinnati Pension (Covington KY) IFEBP Employee Benefits (San Diego CA) 12 IFEBP Employee Benefits (San Diego CA) 13 IFEBP Employee Benefits (San Diego CA) 14 IFEBP Employee Benefits (San Diego CA) THANKSGIVING DATAIR closed 23 DATAIR closed

14 12/17/12: PYE 2/29/11 extended 12/31/12: PYE 5/31/12 December Return of 2011 Excess Contributions with 10% penalty. Alternative notice for DB statements. RMD distributions (over age 70½). Deadline for 2012 interim amendments (if required) Safe Harbor notice and 2012 Supplemental Safe Harbor notice. Annual qualified default investment alternative (QDIA) notice. Annual automatic contribution arrangement notice (QACA) HANUKKAH 16 IRS FIRE System down for maintenance through end of year WINTER BEGINS 15 SAR distributed (if 5500 extension). Notice for PBGC DB Plans electing audit waiver (5500 extended) DATAIR closed 12: CHRISTMAS DAY DATAIR closed 26 KWANZAA BEGINS [see top of page]

Employee Benefit Systems, Inc.

Employee Benefit Systems, Inc. EGTRRA and PPA Restatement Deadlines EGTRRA: Prototype and Volume Submitter DB Documents: April 30, 2012. Individually Designed Plan Documents (both DB and DC) based on last