• Comply with Items on All Qualified Plans List:  The items on the All Qualified Plans list also apply to defined benefit plans.
  • Post Portions of Form 5500 on Company’s Intranet:  The Pension Protection Act of 2006 requires a sponsor of a defined benefit pension plan that maintains an intranet website for the purpose of communicating with employees (and not the public) to post portions of the defined benefit plan’s Form 5500 on the intranet.   
  • Comply with Annual Funding Notice to Participants:  The Pension Protection Act of 2006 requires single employer defined benefit plan sponsors to provide participants with an annual notice of the plan’s funding status within 120 days of the end of the plan year to which the notice relates.  Plans with fewer than 100 participants do not have to provide the notice until the Form 5500 annual report is due for the plan year. 
  • Comply with Participant Notice Requirement if Adjusted Funding Target Attainment Percentage is Less than 80%:  In addition to the annual funding notice described above, Section 101(j) of ERISA requires a plan administrator to provide a notice to participants if the plan is subject to a restriction on payment of benefits.  These restrictions become applicable if the plan’s adjusted funding target attainment percentage is less than 80%.  Plan administrators are not required to provide this notice to participants and beneficiaries in pay status. 
  • Comply with PBGC Notice Requirement if Funding Target Attainment Percentage is Less than 80%:  Plan sponsors of defined benefit plans are required to notify the PBGC if the plan has a funding target attainment percentage of less than 80%.  This filing is due within 105 days following the end of the plan sponsor’s fiscal year, which is April 15, 2013 for calendar year taxpayers. 
  • Provide Participant Benefit Statements:  The Pension Protection Act of 2006 requires defined benefit plans to provide individual benefit statements every three years or upon request.  Alternatively, defined benefit plans may satisfy the requirement by annually notifying participants that the pension benefit statement is available and how a participant may obtain such statement.
  • Amend Plans to Comply with Funding-Based Benefit Restrictions of Section 436 of the Code:  IRS Notice 2011-96 extended the deadline for plan sponsors to amend their plans to comply with Section 436 of the Internal Revenue Code of 1986, as amended (the “Code”), which imposes benefit restrictions on certain underfunded defined benefit pension plans.  Plan sponsors now must amend their plans by the latest of (1) the last day of the first plan year that begins on or after January 1, 2012, (2) the last day of the plan year for which Section 436 is first effective for the plan or (3) the due date (including extensions) of the employer’s tax return for the tax year that contains the first day of the plan year for which Section 436 is first effective for the plan. This means that calendar year, non-collectively bargained plans must be amended by December 31, 2012.
  • Provide Suspension of Benefits Notice, if applicable:  If required by the terms of the plan, plan administrators must provide notice of the suspension of benefits to participants who continue employment beyond normal retirement age and to rehired retirees.  This notice should be given during the first month during which the benefit is suspended.