SECURE 2.0 has provided new options for plan sponsors when distributing notices to plan participants. Previously, all required notices must be distributed to all plan participants whether or not they had enrolled in the plan or had an account balance. Effective for plan years beginning after December 31, 2022, plan sponsors of defined contribution plans now have the option to forgo providing notices to those eligible but not participating and with no account balance, providing the following conditions are met:
- Participants received a copy of the Summary Plan Description and all required notices when first becoming eligible for the plan.
- Participants receive a separate annual notice reminding them of their eligibility for the plan. This notice must be provided within a reasonable period before the beginning of each plan year.
- Participants must be provided any notices upon request.
Although plan sponsors now have the option to exclude some participants from receiving certain notices, the task of segregating participants into two categories and tracking the notices may be too much of an administrative burden. It may just be easier to supply all notices to all participants.