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Keep This 2020 Fiduciary Calendar Handy
January 21, 2020

As a retirement plan sponsor, you are responsible for fulfilling fiduciary duties associated with your plan throughout the year. This makes now a good time to plan ahead by preparing an annual fiduciary calendar.

Here are some of the main fiduciary tasks that you should put on your 2020 calendar:

First Quarter (January 1–March 31)

• Prepare and review the annual census report for compliance testing. Each year, you are responsible for providing a comprehensive census report to your third-party administrator (TPA) and other relevant service providers.

• Prepare an annual schedule of contribution remittances. Shortly after year end, reconcile remittances by pay date to the W-2 total and total deferrals remitted to the plan to ensure that contributions are timely and complete.

• Make sure employee compensation aligns with the plan’s definition of eligible compensation.

• Approve the TPA’s compliance results. You should also carry out any needed corrective action at this time.

Second Quarter (April 1–June 30)

• Schedule your plan’s independent audit. Or you may simply need to determine whether an initial audit is necessary.

• Prepare for your plan’s independent audit. Gather meeting minutes, plan amendments, census data, compliance testing results and third-party reports.

• Coordinate with plan service providers. You’ll want to get commitments from your service providers regarding completion dates for the plan audit.

Third Quarter (July 1–September 30)

• Complete your plan audit by July 31 and file Form 5500. Or you can file for an extension until October 15.

• Take corrective action to fix any operational errors that the audit uncovered. You may be able to use the IRS Self-Correction Program (SCP) or Voluntary Correction Program (VCP).

Fourth Quarter (October 1–December 31)

• Review your plan design. This should include determining whether there are any new regulations or amendments you need to implement.

• Evaluate the effectiveness of your plan’s internal controls. Strong internal controls are essential to ensuring that your plan remains in compliance with all regulatory requirements and plan provisions and guarding against fraud.

• Distribute required plan notices to participants. These typically include safe-harbor matching contributions and Qualified Default Investment Alternative (QDIA) notices. If the plan is changing service providers at year end, notify participants.

• Approve discretionary employer contributions going into the next year. Also make sure these are documented in the meeting minutes.

Keep It Handy

You should keep this fiduciary calendar handy to ensure that you accomplish the tasks required throughout the year to fulfill your fiduciary duties as a retirement plan sponsor.

2020 ERISA Compliance Deadlines

In addition to the fiduciary duties listed on this page, you are also required to complete a variety of ERISA compliance tasks throughout the year. Here are the 2020 plan year deadlines for some of the most common ERISA compliance tasks that sponsors of qualified retirement plans require:

30-90 days before implementation/enrollment
Provide applicable 2020 safe harbor 401(k) plan and QDIA notices

2/14/20
Provide fourth-quarter benefit statements to participants                             

3/13/20
Make 2019 employer contributions in order to take a deduction in fiscal year 2019 (unless extension filed)

4/1/20
Distribute first-year Required Minimum
Distributions (RMDs) to participants who turned 70.5 in 2019

5/15/20
Provide first-quarter benefit statements to participants                                

7/31/20
File 2019 Form 5500 or extension (Form 5558)                       

8/14/20
Provide second-quarter benefit statements to participants

9/15/20
Make 2019 employer contributions in order to take a deduction in fiscal year 2019 (if extension filed)

10/1/20
Distribute 2019 Summary Annual Report (SAR) to participants if Form 5500 filed on time

10/15/20
File 2019 Form 5500 (if extension filed)

11/13/20
Provide third-quarter benefit statements to participants

30-90 days before implementation/enrollment
Provide applicable 2021 safe harbor 401(k) plan and QDIA notices

12/15/20
Distribute 2019 Summary Annual Report (SAR) to participants if Form 5500 extension is filed

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