How Can I Know Unless You Tell Me? New Rules for Participant Disclosures: Are They Any Easier?

October 31, 2023 (4 min read)

SECURE 2.0 gave some leeway to plan sponsors in revising their participant notice distribution options. Effective this year, defined contribution plan sponsors have the option to forgo providing notification to unenrolled participants (with zero account balances). Certain conditions apply like (1) SPDs are still required, as are initial notices, like initial QDIA notices, (2) annual eligibility notices are still required (to be provided a reasonable time before the plan year begins), and (3) all participants must be provided notices on request. 401(k) plans with auto enrollment likely won’t have participants with zero accounts, except opt-outs. These disclosure rules may have minimum impact in reducing plan administration, but simplification was their goal.

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