StargazerL81
Jun 29 2004, 10:14 AM
May the written explanation of a QPSA be included in the SPD or must it be a separate written explanation?
MBL
HarveyC
Jul 2 2004, 11:11 AM
I have had some clients indicate that they comply with the QPSA/QJSA notice requirements via posting in SPD but I have advised that this is not a sufficient delivery method.
§1.417(a)(3)-1(a)(3) says...
Required method for providing section 417(a)(3) explanation. A section 417(a)(3) explanation must be a written explanation. First class mail to the last known address of the participant is an acceptable delivery method for a section 417(a)(3) explanation. Likewise, hand delivery is acceptable. However, the posting of the explanation is not considered provision of the section 417(a)(3) explanation.