If the plan's recordkeeper is not going to provide vesting information on their statements so that the plan will instead be providing an annual vesting statement, does anyone know when the first statement must be provided?

Assuming the plan is participant directed, would the first annual notice need to be provided by the date the first quarterly statement is due, I believe May 15, 2007? Or is some later date acceptable?

Thanks!

If the plan year begins anytime during January 1-March 31, then the first quarterly statements for a self-directed plan will be due May 15. Those statements must include individual vesting information.

It was my understanding that in lieu of vesting actually on the statement, an annual vesting notice could be provided. Apparantly not all service providers are planning to put vesting on their quarterly statements.

My question is, if the plan is going to be providing the annual vesting statement, and let's assume a calendar year plan, when is the annual statement due?

My guess, after reading EBSA FAB 2006-3, is 12/31/07 or 2/14/08.

12/31/07 is based on the following in FAB 2006-3:

"The alternative notice requirement for defined benefit plans provides that the requirements of section 105(a)(1)(B)(i) shall be treated as met with respect to a participant if at least once each year the administrator provides the participant notice of the availability of the pension benefit statement and the ways in which the participant may obtain such statement. If a plan elects to take advantage of the alternative notice provision in section 105(a)(3)(A), the required notification must be furnished not later than December 31, 2007."

2/14/08 is based on the following in FAB 2006-3:

"Pending the issuance of further guidance, it is the view of the Department that the furnishing of pension benefit statement information not later than 45 days following the end of the period (calendar quarter or calendar year) will constitute good faith compliance with the requirement to furnish a pension benefit statements in accordance with section 105(a)(1)(A)(i) and (ii)."

Given the potential $100/day/participant penalty, I would use 12/31/07 until EBSA guidance.