Compliance Calendar

Event

Due Date

Reason

Plan sponsor sends data to Focus First Quarter Plan sponsor reconciles data and sends to Focus (with enough time for Focus to perform compliance tests)
Plan sponsor engages CPA for plan audit First Quarter If the plan has over 100 participants or does not meet an exception, engagement and scheduling should occur
Plan sponsor engages valuation firm First Quarter If the trusts invests in non-publicly traded securities (company stock, real estate, etc.), engagement and scheduling should occur
Finalize trust statements First Quarter Trust statements should be forwarded to Focus for reconciliation
Participant statements to plan sponsor Within 4-6 weeks after receiving info The actual date will vary depending upon the receipt of data and financials as well as the work necessary to reconcile, allocate and perform discrimination testing
Form 1099-R January 31 Participants who receive a distribution
Form 945 January 31 Tax withholding from participants receiving distributions
Form 1096 February 28 Transmittal form for Forms 1099-R
Contributions to trust for deduction March 15 Employer contributions are deductible by the due date of the corporate tax return
Compliance refunds without penalty March 15 Failures of certain discrimination tests requiring refunds to participants
ESOP diversification election forms due March 31 ESOP participants who are age 50 with 10 years of participation may elect to diversify a portion of their account
Minimum required distributions April 1 First payment to 5% owners or non-5% owners electing to receive a distribution
Correction of excess deferrals April 15 Refunds to participants who exceed maximum deferrals
ESOP diversifications executed June 30 ESOP participants who elected diversification by March 31 should have their instructions executed by this date
Plan sponsor prepares mid-year data and sends to Focus July If projections are wanted to gauge discrimination testing
Form 5500 or Form 5500-EZ original due date July 31 Annual return due
Form 5558 due date July 31 Application for extension of annual return
Contributions to trust for deduction September 15 Employer contributions are deductible by the extended due date of the corporate tax return
Summary Annual Report September 30 If the Form 5500 was filed by July 31
Data request prepared and sent to plan sponsor November 1 – January 31
Summary Annual Report December 15 If the Form 5500 was extended and filed by October 15
Complete any prior year contributions or corrections December 31 ERISA requires compliance by the end of the year of the year following the event
Minimum required distributions December 31 Annual payment to 5% owners or non-5% owners electing to receive a distribution