Employers: Have you made your fiduciary resolutions?

Sean Jordan

By Sean Jordan
Sean Jordan is Head of Emerging Client Management for the Workplace Solutions unit of MassMutual.
Posted on Jan 15, 2020

Champagne toasts … earnest resolutions to lose weight, exercise more or otherwise improve … endless days of college football bowl games. The New Year brings many rituals, among them the posting of new calendars and the marking of holidays, vacations, birthdays and other special dates.

Employers that sponsor retirement plans keep a similar but separate calendar specifically to track fiduciary duties associated with managing a defined contribution plan, defined benefit plan or both. Many of the dates are critical, meaning that the potential problems caused by missing a to-do on the calendar can make a New Year’s Day hangover welcome by comparison.

For instance, do you know when to file Form 945, which reports Form 1099-R tax withholdings? What is the deadline to make a corporate employer contribution to a retirement plan for the prior fiscal year to be eligible to take a tax deduction for prior fiscal year? You definitely don’t want to miss the deadline to request IRS waiver if your plan fails to meet minimum funding requirements. Already, the champagne’s bubbles are going flat.

Fear not. MassMutual helps employers that sponsor retirement plans potentially avoid potential headaches by helping them navigate fiduciary deadlines and duties by annually publishing a fiduciary calendar. The calendar includes separate dates and deadlines for defined contribution plans such as 401(k)s and defined benefit plans such as pensions and cash balance plans. Pinups not included.

Most employers stay on top of their fiduciary obligations, especially large companies with staffs dedicated to managing their retirement plans. But the requirements are not always clear cut or necessarily understood by everyone, especially for newer plan sponsors. For instance, deadlines and requirements may vary by plan type such as multiple employer plans (MEPs), Taft-Hartley plans, certain union plans, governmental and tax-exempt plans.

Several key dates that relate to retirement plan regulatory filings and other plan action items are sprinkled throughout the calendar year (and, as applicable, the plan year). Some items such as notifications about Qualified Default Investment Alternatives (QDIAs), Safe Harbors, deposit of employee contributions and other activities recur annually or more often. The calendar provides a separate list of such activities for quick reference.

While the calendar is helpful, it’s only a starting point. Retirement plan sponsors seeking deeper insights and explanations are urged to reach out to their financial advisors or third-party administrators (TPAs). Advisors and TPAs work closely with recordkeepers such as MassMutual to keep abreast of important dates and deliverables.

MassMutual’s relationship managers and client engagement managers are also available to help. They are up to speed on regulatory requirements, filing dates and other obligations. Help is never farther away than a phone call or email.

Of course, you should always consult your own tax and legal advisors about your fiduciary requirements. The information contained in MassMutual’s Fiduciary Calendar is not intended or written as specific legal or tax advice and should not be deemed, relied upon or considered for the purposes of avoiding any federal tax penalties. Neither MassMutual nor any of its employees or representatives is authorized to give tax or legal advice.

Necessary disclosure aside, MassMutual’s fiduciary calendar is a good starting point to keep tabs on fiduciary obligations. Plan sponsors are encouraged to review the calendar in its entirety to map out necessary filings, gather necessary data, and reach out early to ask questions about or clarify requirements for any ambiguous or esoteric filing requirements.

So start the New Year with another ritual: diligently following the fiduciary calendar. Doing so can help sponsors avoid pitfalls and score another successful year for retirement savings. And that’s worth toasting.

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The information provided is not written or intended as specific tax or legal advice. MassMutual, its employees and representatives are not authorized to give tax or legal advice. You are encouraged to seek advice from your own tax or legal counsel. Opinions expressed by those interviewed are their own and do not necessarily represent the views of Massachusetts Mutual Life Insurance Company.