Reporting and Disclosure Requirements for Non-ERISA Plans

March 24, 2014 ( – Financial and retirement services provider Prudential has created a 2014 Compliance Checklist for retirement plans that are not governed by the Employee Retirement Income Security Act (ERISA).

The checklist is for qualified governmental and nonelecting church plans, non-ERISA 403(b) plans, 457 plans and nonqualified executive benefit plans that are not subject to ERISA. It offers sponsors of non-ERISA plans information about the materials that need to be filed, as well as filing due dates and the agencies these materials need to be routed to.

The checklist is divided into two broad reporting categories: Participants and Beneficiaries; and Internal Revenue Service (IRS). These categories each contain five sections that include:

  • Status: to monitor the activity for each item that applies to your plan;
  • Plan: indicates if the item applies to a:
    • qualified governmental or nonelecting church defined benefit plan;
    • qualified governmental or nonelecting church defined contribution plan;
    • non-ERISA 403(b) plan;
    • Section 457(b) plan; and/or
    • unfunded nonqualified plan;
  • Item: the task;
  • Action/Support: what must be completed for each item; and
  • When Due: deadline or completion time frame for each item.

The checklist also makes mention of special reporting requirements for nonqualified top-hat retirement plans if they are unfunded.

The information presented in the checklist reflects reporting and disclosure requirements in effect as of January 1, 2014, according to Prudential.

A copy of the compliance checklist for non-ERISA plans can be downloaded here.