Apex Pension Strategies the TPA Service 02 / 04
THE SAME PEOPLE,
EVERY YEAR.
Administration is the recurring work of operating a qualified plan: eligibility and vesting tracked, contributions reconciled against payroll, distributions checked against the document, notices sent, the valuation run and the Form 5500 filed. The calendar does not negotiate.
The people who run your plan this year ran it last year, which matters when somebody asks why a 2019 entry date was coded that way.
The year in five dates
2026 dates, for the 2025 plan year- Feb 2
- Form 1099-R copies to recipients, and Form 945
- Mar 31
- Form 1099-R filed electronically with the IRS
- Jul 31
- Form 5500 and Form 8955-SSA, or Form 5558 to extend them
- Oct 15
- Extended Form 5500 and Form 8955-SSA
- Dec 15
- Summary Annual Report, on the extended track
THE PLAN YEAR, IN ORDER.
Apex Pension Strategies, Inc. describes the job in one sentence: “As the third party administrator, we ensure the legal and operational aspects of the plan are followed and maintained, processes are established where needed and participants are timely informed and paid according to the terms of the plan.” What follows is what that costs in a year.
The work, itemized
- Eligibility and entry tracking, so nobody is let in early or left out late.
- Vesting calculated from the service records.
- Employer contributions calculated and allocated the way the document says.
- Deferrals and contributions reconciled against payroll and the recordkeeper.
- Distributions, loans, hardships and QDROs reviewed against the plan’s terms before anything is paid.
- The annual valuation and participant allocations for balance-forward plans.
- Participant notices and statements, scheduled to their deadlines.
- Signature-ready Form 5500 and Form 8955-SSA from reconciled data.
- Form 1099-R for the distributions, Form 945 for the withholding.
- Coordination with your recordkeeper, payroll provider, advisor and auditor.
Testing runs on this same data and has a page of its own: every test the plan is subject to, and what a failure costs.
The year, part by part
January to March
Last year’s distributions are reported before this year’s work starts. The census request goes out with them.
- Feb 2
- Form 1099-R copies to recipients, and Form 945 for the withholdingJanuary 31 fell on a Saturday
- Mar 2
- Form 1099-R paper filing with the IRSFebruary 28 fell on a Saturday
- Mar 31
- Form 1099-R electronic filing with the IRS
April to June
The census is reconciled against the payroll register and the recordkeeper, contributions are allocated the way the document says, and the testing is worked while it can still change something.
No filing date falls here. This is the part of the year the filings are made out of.
July to September
The return goes over signature-ready. Extending is a July decision: a Form 5558 filed after the due date is not an extension.
- Jul 31
- Form 5500, Form 5500-SF and Form 8955-SSA for the 2025 plan year. Form 5558 must be filed by this date to extend them.
- Sep 30
- Summary Annual Report, where the Form 5500 was not extended
October to December
The extended filing closes, statements and the next year’s notices go out, and the year gets read.
- Oct 15
- Extended Form 5500 and Form 8955-SSA
- Dec 15
- Summary Annual Report, where the Form 5500 was extended
2026 dates, for a calendar-year plan’s 2025 plan year. A date falling on a weekend moves to the next business day.
ALMOST NEVER THE DOCUMENT.
ALMOST ALWAYS PAYROLL.
The compensation definition in the document does not match the earnings code payroll uses. A deferral election changes and takes effect a pay period late. Bonus pay is left out when the document includes it. A new hire’s entry date is missed because eligibility is calculated from hire dates rather than hours.
None of those announce themselves. They surface a year later in testing, or three years later in an examination, by which point the correction is larger than the error. So we reconcile through the year rather than in one January pass, and we ask for the payroll register: a summary is where a mismatch hides.
What we need back repeats: a census once a year, payroll detail with each contribution, and a call when something changes.
WHAT ARRIVES, AND WHEN IT HAS TO.
Almost everything a participant receives has a deadline on it, and a missed notice is the quietest failure in this business: nothing goes wrong in the year you miss one, and then it is a finding.
- Summary plan description
- Within 90 days of becoming covered by the plan.
- Account statements
- At least quarterly for a participant-directed plan.
- Annual fee disclosure
- Once a year, to everyone eligible, including those who have not joined.
- Summary Annual Report
- September 30, 2026 for the 2025 plan year, or December 15, 2026 where the Form 5500 was extended.
- Safe harbor notice
- Thirty to ninety days before the plan year begins, for a match design.
- Automatic enrollment and default investment notices
- Before each plan year, and before a contribution can be defaulted into the qualified default alternative.
The safe harbor notice goes wrong in both directions. It was removed for nonelective designs, so a plan still sending one out of habit no longer needs to. It was not removed for match designs, or for a nonelective plan that also uses a match to satisfy the ACP safe harbor.
THE WORK MOVES.
THE TITLE STAYS.
Administration is not the same thing as being the plan administrator, and the difference is legal. Your company is the plan sponsor. Under ERISA the plan administrator is the party responsible for operating the plan: the Form 5500 filing, the notices, a claim when a participant disputes a distribution. Unless the document names somebody else, that is your company as well, and it sits with whoever signs.
Apex Pension Strategies, Inc. does the work. The employer keeps the title, and signs.
- The Form 5500
We prepare it from reconciled data, ready for signature.
The employer signs it.
- Participant notices
We draft them, date them, and say what goes out when.
They go out over the employer’s name.
- A disputed claim
We read the document and set out what its terms say about the account.
The named plan administrator decides the claim.
- The plan document
We keep it, amend it when the law moves, and say what changed.
The employer adopts and executes it.
The deposit rule, honestly
Employee deferrals have to reach the trust as soon as they can reasonably be segregated from the employer’s general assets. A plan with fewer than 100 participants has a seven-business-day safe harbor. A larger plan has none, and is measured against the fastest deposit that employer has managed.
If you want the title to move as well
That is a different engagement, at a different price and a different level of accountability. Apex Fiduciary Services, LLC can be named the ERISA 3(16) plan administrator and take those duties on in writing. We would rather you knew which job you were buying.
THE YEAR, READ BACK TO YOU.
The part that gets left out is telling you what the year meant. We explain the design back to you and project what the plan produces, so you can describe it to your own employees.
Then the numbers. Testing margins that thin every year mean a design change is coming, even in a year that passed. Participation falling in one location and not another is usually an enrollment problem rather than a plan problem. Loan volume that jumps is worth a conversation. It goes into a short note, and where it points somewhere, consulting starts.
We do not give legal or tax advice, and we never manage the investments.
Where this goes next
SEND US THE LAST 5500.
Send your plan document and your last Form 5500. We will read them against each other and tell you what we would do differently and what we would need from you through the year.
- PO Box 88208, Atlanta, GA 30356
- Telephone
- (770) 410-5022
- Practice
- Third-party administration
