A comparison of qualified retirement plansFOR EMPLOYER USE ONLY. NOT FOR USE WITH EMPLOYEES.

E M P LOY E R

Key employee – An employee who at any time during the plan year containing the determination date is:

1) an officer with annual compensation greater than $185,000; or

2) a more than 5% owner (family attribution rules apply); or

3) a more than 1% owner with annual compensation greater than $150,000 (family attribution rules apply).

Top-Heavy Plan – Occurs when, on the determination date (last day of prior plan year or, in the case of a plan’s first plan year, the last day of that plan year):

• in defined contribution plans, the total of the accounts of all key employees exceeds 60% of the  total of all the accounts;

• in defined benefit plans, the present value of the accrued benefits of all key employees exceeds 60% of the present value of the accrued benefits of all employees;

• in IRS SARSEP (Form 5305A-SEP) plan, when more than 60% of all contributions go to key employees.

Safe Harbor 401(k) plans consisting solely of deferrals and Safe Harbor contributions are deemed to satisfy top-heavy rules.

SIMPLE plans that permit no contributions other than those required by Internal Revenue Code § 401(k)(11) are deemed to satisfy top-heavy rules.

• A minimum contribution to each non-key employee’s account who is a plan participant of up to 3% of compensation for defined contribution plans and SARSEPs; and a minimum benefit of up to 20% for defined benefit plans (2% of compensation per year of service, up to a maximum of 10 years) is required. If a non-key participant benefits under both a defined contribution and a defined benefit plan, the defined benefit plan can provide a minimum benefit of at least 2% of average annual compensation, not to exceed a total of 20%. However, if the employer chooses to have the defined contribution plan provide the top-heavy minimum benefit, the defined contribution plan must contribute at least 5%.

• Accelerated vesting:

Key employees and top-heavy requirements

FOR EMPLOYER USE ONLY. NOT FOR USE WITH EMPLOYEES.

Highly compensated employees (“HCEs”) for 2020An employee is considered highly compensated if the employee:

1) was a more than 5% owner in either 2019 or 2020; or

2) an employee who earned over $125,000 in the preceding year (2019).* An employer may also elect to consider the top 20%** of employees as HCEs (the top-paid group).

* For the 2021 plan year, an employee who earns more than $130,000 in 2020 is an HCE.** If the plan document defines HCE, then the top-paid group election must be a plan provision in the plan document. All plans of the employer

(and controlled group members) must adopt this election if one plan has made this election. This election applies to all tests.

ServiceVested

percentageGraded schedule 2 years 20%

3 years 40%4 years 60%5 years 80%6 years 100%

Cliff schedule 3 years 100%

FOR EMPLOYER USE ONLY. NOT FOR USE WITH EMPLOYEES.

Types of qualified retirement plansProfit Sharing Plans – and 401(k) Plans allow for a discretionary contribution by the employer. The 401(k), Safe Harbor 401(k) and SIMPLE 401(k) Plans include pre-tax employee salary deferrals.

• Profit Sharing Plan*• 401(k) Plan*• SIMPLE 401(k)*• Safe Harbor 401(k)*

Pension Plans – They offer a fixed commitment to provide a benefit or to make a contribution for the participant based on a stated formula in the plan:

• Cash Balance Plan• Defined Benefit Plan• Target Benefit Plan*• Money Purchase Plan*

Defined Contribution Plans – They are listed above with an asterisk (*), and have participant accounts which are subject to the earnings of the investments held by the plan. The retirement benefit is based on the accumulation of dollars in the participant’s account.

Defined Benefit Plans – They provide for a stated monthly retirement benefit which is funded by the employer. The plan costs are based on the assumptions set by an Enrolled Actuary. These plans are also covered by the Pension Benefit Guaranty Corporation (PBGC) (unless exempt). Fully Insured Defined Benefit Plans (412(i) plans)  do not need an Enrolled Actuary.

Section 403(b) Plans – A deferred compensation program (also referred to as a tax sheltered annuity) which is a special type of retirement plan for public education organizations and certain tax-exempt organizations. A section 403(b) plan is not considered a“qualified plan” under IRC 401(a).

Section 457 Plan – a “nonqualified” deferred compensation Plan that is maintained by an eligible employer — which may be a State, a political subdivision of a State, an agency or instrumentality of a State or a tax-exempt organization. There are two types of plans under IRC Section 457: 457(b) plans and 457(f) plans. A 457(f) plan is often referred to as an "ineligible" 457 plan and may only be sponsored by a not-for-profit organization.

Other types of retirement plansSimplified Employee Plans – SEPs – This plan works like a profit sharing plan. The employer’s contribution is discretionary. Contributions go directly to a traditional retirement account or a traditional retirement annuity (SEP-IRA) of each eligible employee.

Salary Reduction Simplified Employee Pensions – Grandfathered SARSEPs – A SARSEP is a SEP set up before 1997 which allows eligible employees to make pre-tax salary deferrals into their IRA. No new SARSEPs may be established after 12/31/96.

SIMPLE IRAs – Allow employees to make pre-tax salary deferrals into a SIMPLE IRA account with an employer match or employer non-elective contribution.

SEP/SARSEP (1) SIMPLE IRA (2) SIMPLE 401(k) (3) Profit Sharing (4) 401(k) (5) Safe Harbor 401(k) (6) QACA5 (7) Money purchase (8) Defined Benefit (9) 403(b) (10) GOVERNMENTAL 457(b) (11)Deadline for establishing the Plan No later than due date (including

extensions) for filing employer’s tax return. (No new SARSEPs after 12/31/96.)

Generally, no later than Oct. 1 of a calendar year.1

Employer with 100 or fewer employees that does not maintain another qualified plan.

Same as (2) No later than plan year-end Same as (4) In general, a Safe Harbor 401(k) plan must be adopted before the beginning of the plan year, at least by October 1 for a calendar year plan.4

Same as (4) Same as (4) No later than plan year-end – does not have to match fiscal year No later than plan year-end No later than plan year-end

Deadline for making contribution Note: Employee salary deferrals should be deposited into the plan as soon as administratively feasible

Employer Required Contribution — no later than due date including extension for filing employer’s tax return.

Employee salary deferrals no later than 30 days following month withheld. Employer required contribution — same as (1).

Employee salary deferrals no later than 15 business days following month withheld.3 Employer required contribution — same as (1).

Same as (1) Same as (3) Same as (3) Same as (3) Contributions must be made no later than 8½ months after plan year-end.

Quarterly: by 15th day after each quarter of the plan year. Interest penalties are charged if paid later Annual: Contribution deadline is 8½ months after plan year-end

Non-ERISA (with only salary deferral) – no longer than is reasonable for proper administration ERISA – Employee salary deferrals no later than 15 business days following month withheld Employer contribution may be made any time during calendar year

457(b) (with only salary deferral contributions) – salary deferral ongoing from payroll. May include designated Roth program.

Maximum permitted eligibility requirements Eligibility requirements may always be less restrictive

Age 21 and worked for the employer at least 3 of the 5 preceding years; has received at least $600 in compensation in 2020 from the employer (subject to annual cost-of-living adjustments).

Must be offered to all employees who have compensation of at least $5,000 in any 2 preceding years (whether or not consecutive) and expected to receive at least $5,000 in current calendar year.

Age 21 and 1 year service (1,000 hours)

Age 21 and 1 year service (1,000 hours) with graded vesting or 2 years of service with 100% vesting

Age 21 and 1 year of service (1,000 hours) with graded vesting or 100% cliff vesting.

Age 21 and 1 year of service (1,000 hours)

Same as (6) Same as (4) Same as (4) Universal Availability requires all employees to be eligible to defer, with a few exceptions: • Work less than 20 hours per week • Eligible to participate in another 403(b), 401(k) or governmental 457(b) • Non-resident Alien

None

Vesting: Top-Heavy

Non–Top-Heavy Contributions are immediately 100% vested.

Employer contributions and employee salary deferrals are immediately 100% vested.

Same as (2)2 yrs. = 20% to 6 yrs. = 100% or 3 yrs. = 100%

Same as (4) and Employee salary deferrals are immediately 100% vested.

Employer required Safe Harbor contributions and Employee salary deferrals are 100% vested.All other employer contributions same as (5)

Deferrals 100% immediately vested Safe Harbor contributions subject to 2-year cliff Schedule

Same as (4) 2 yrs. = 20% to 6 yrs. = 100% or 3 yrs. = 100%

3 yrs. = 20% to 7 yrs. = 100% or 5 yrs. = 100%

Non-ERISA — not subject to ERISA vesting ERISA — 2 yrs. = 20% to 6 yrs. = 100% or 3 yrs. = 100% or any schedule at least as generous. Employee salary deferrals are 100% vested. Contributions must count for §415 limits only when fully vested

Employee salary reduction contributions are immediately 100% vested. However, if an employer contribution is not 100% immediately vested, the contribution is not included in the contribution limit test until it becomes vested.11

Compensation: $600 — 2020 minimum $285,000 — 2020 maximum

No maximum for employee salary deferrals and employer match. $285,000 — 2020 (for employer 2% non-elective contribution)

$285,000 — 2020 maximum Same as (3) Same as (3) Same as (3) Same as (3) Same as (3) Same as (3) $285,000 for 2020 No limit

Contribution and benefits limit per participant

Annual additions not to exceed lesser of 25% of compensation or $57,000 (25% of compensation for SARSEP) Employee salary deferrals in SARSEP limited to $19,500 ($6,500 catch-up at age 50 or older for SARSEPs) — 2020Employees can’t make elective deferrals for a year if the employer had more than 25 employees who were eligible to participate at any time during the preceding year.

Employee salary deferrals limited to $13,500 ($3,000 catch-up at age 50 or older) — 2020Employer required contribution of: 1) $1 for $1 match up to 3% of pay*; or 2) 2% of pay non-elective * can be reduced to as low as 1% in any 2 years out of 5

Employee salary deferrals limited to $13,500 ($3,000 catch-up at 50 or older) — 2020Employer required contribution of: 1) $1 for $1 match up to 3% of pay; or 2) non-elective contribution of 2% of

each eligible employee’s pay

Annual additions not to exceed lesser of 100% of compensation or $57,000 ($63,500 including catch-up contributions) — 2020Contribution limits are the lesser of 25% of compensation or $57,000.

Employee salary deferrals Limited to $19,500 ($6,500 catch-up for 50 and older) — 2020Annual additions not to exceed lesser of 100% of compensation or $57,000 ($63,500 including catch-up contributions) — 2020

Same as (5) Employer Safe Harbor required contribution of: $1 for $1 match up to 3% of pay PLUS $.50 for $1 on next 2% of pay; or at least 3% of pay non-elective contribution for all eligible employees. (A contribution of greater than 3% is permitted.)

Same as (5) Employer Safe Harbor required contribution of: $1 for $1 match up to 1% of pay PLUS $ .50 for $1 on next 5% of pay; or 3% of non-elective contribution. Auto enrollment of 3%; Auto Deferral Increase to 6% not to exceed 10%.

Same as (4)The plan document states the required contribution percentage.

Benefit not to exceed lesser of 100% of compensation (3-yr. average) or $230,000 — 2020 (reduced for normal retirement age below 62 and for years of plan participation less than 10)

Annual additions not to exceed the lesser of 100% of compensation or $57,000 (2020)Employee salary deferrals limited to $19,500. Catch-ups for employees age 50 or over — additional salary reduction contributions of $6,500 beyond the basic limit.Catch-ups for employees with 15-years of service6 is available for:• Selected employers (public school system, hospital, home health

service agency, health and welfare service agency, church, or convention or association of churches (or associated organization)

• Limited to least of:1) $3,0002) $15,000 less previously excluded special catch-ups, or3) $5,000 multiplied by years of service minus previously

excluded deferrals

Employee salary deferrals limited to lesser of $19,500 or 100% of compensation. Special catch-up provisions may increase this limit. Employer contributions offset employee contributions. Employer contributions are permissible but not required.Age 50 or over — additional salary reduction contribution $6,500 (2020) If permitted by the plan, special 457 catch-up: • 3 years prior to the year of normal retirement age • limited to the lesser of:

1) $39,000 (twice the basic annual limit) for 2020 or 2) the basic annual limit plus underutilized basic annual limit in prior years

Note: Can’t use the increased limit if using age 50 catch-up contributions. In years when employee is eligible to take advantage of both, the employee can use the higher of the two increases to the limit.

Top-Heavy minimum contributions/benefits for non-key employees

Minimum contribution is lesser of 3% of compensation or the greatest contribution % made for a key employee.

Not applicable Not applicable Same as (1) Same as (1) None needed if plan year contributions consist solely of elective deferrals and Safe Harbor contributions.

Same as (6) Same as (1) Minimum Accrued Benefit of 2% of average compensation per year of service, up to a maximum of 10 yrs. (= 20%)

Not applicable

Employer deduction limitations Lesser of its contributions or 25% of compensation of participating employees. Deferrals fully deductible.

Employer required contribution is deductible.

Same as (1) 25% of compensation paid (or accrued) during the year to eligible employees participating in the plan.

Same as (1) Same as (1) Same as (1) Same as (4) Amount necessary to fund benefit as determined by the Enrolled Actuary.

Not applicable Not applicable

Participant loans Not permitted Not permitted Plans may permit loans. Participant may borrow $10,000 or the lesser of 50% of vested account balance, or $50,000.Prior outstanding loan balances in past year must also be considered.

Same as (3) Same as (3) Same as (3) Same as (3) Same as (3) Same as (3), substituting vested accrued benefit for vested account balance.

Yes Yes

Government reporting to: None None DOL/IRS filing (e.g. 5500 filings)2 Same as (3) Same as (3) Same as (3) Same as (3) Same as (3) Same as (3) plus PBGC filing(s) (unless exempt) Non-ERISA: None/ERISA: Yes, same as (3) No

C O M P A R I S O N O F B A S I C T Y P E S O F E M P L O Y E R R E T I R E M E N T P L A N S

7 Please refer to the 2020 Fiduciary Calendar for Non-Calendar Plan Year deadlines. 8 Plans that meet all the EACA requirements, including the annual notice requirement and the requirement that all eligible employees are covered by the EACA for the plan

year, have a six-month period to correct failed ADP/ACP tests before the corrective distributions are subject to an employer paid 10% excise tax.9 Note that all 5500s (except 5500-EZ) are filed electronically using Department of Labor’s EFAST2 system, effective with the 2009 plan year.10 Small Plan Safe Harbor Rule: effective 1/14/2010, provides that employee contributions are deemed timely if deposited no later than the 7th business day following the date

amounts would otherwise have been paid to the employee as compensation or date contributions (including loan repayments) are received by the employer.11 Our 457(b) product is designed for 100% immediately vesting on employer contributions.

Note: The information provided in this comparison is a summary of selected rules governing retirement plans and is not intended to be used as a basis for legal or tax advice.1 For a new employer coming into existence after October 1, a SIMPLE IRA can be set up as soon as administratively possible.2 Effective with the 2009 plan year, all 5500s (except 5500-EZ) are filed electronically, and ERISA 403(b) plans are subject to the full reporting requirements that apply to

private plans.3 Small Plan Safe Harbor Rule: effective 1/14/2010, provides that employee contributions are deemed timely if deposited no later than the 7th business day following date amounts

would otherwise have been paid to the employee as compensation or date contributions (including loan repayments) are received by the employer.

4 A Safe Harbor 401(k) plan may also be designed to eliminate the ACP test requirement for a plan year if: matching contributions cannot be made for employee after-tax or salary deferral contributions in excess of 6% of compensation; the match rate may not increase as the rate of deferral increases; the rate of match for HCEs may not be greater than any rate for the NCHEs; and the plan must meet the ADPS Harbor provisions.

5 A Qualified Automatic Contribution Arrangement (QACA) is an automatic contribution arrangement with special safe harbor provisions that exempt a 401(k) plan from ADP and, if certain provisions are met, ACP testing requirements.

6 If both catch-up provisions apply, the law requires deferrals exceeding the standard limit ($19,500 in 2020) to be first applied to the 15-year catch up (to the extent permitted), and then to the age 50 catch-up.

Note: 1987 is the base year upon which the annual cost of living changes have been made.

Deadlines calendar year plan7 (2019) Action/form name When due

Who is responsible Delivered to

1/1 Participant fee disclosure notice for participant-directed defined contribution plans includes annual disclosure and quarterly disclosure required information. Quarterly disclosure of 404(a) fees informa-tion charged to a participant’s account during the quarter just ended. This information may be included with the quarterly benefit statement for participant-directed defined contribution plans.

Annual Disclosure – Covered participant-directed plans operating on a calendar-year basis had to furnish the annual disclosure (with the comparative chart) no later than August 30, 2012 for the first time and at least annually thereafter. See DOL Field Assistance Bulletin 2013-02 for conditions and details about its extension for delivery of annual fee disclosure notice. Quarterly Disclosure – This provides information about fees and expenses deducted from a participant’s account for the calendar year or plan year quarter to which the statement relates.

Plan Administrator Participants, Beneficiaries

3/15 Corrective Distribution for failed ADP/ACP without 10% Excise Tax8

If fail, correction by 2½ months Employer/Trustee from plan year end

Participant

4/1 (for 1/1 entry) Summary Plan Description Within 90 days of becoming a participant Plan Administrator Participants4/15 Corrective Distribution of 402(g) 4/15 Plan Administrator/

TrusteeParticipant

6/30 To avoid 10% excise tax, distribute a corrective distribution for failed ADP/ACP test if plan meets all the Eligible Automatic Contribution Arrangement requirements.

If fail, correction by 6 months from plan year end

Plan Administrator Participants

7/29 Summary of Material Modifications 210th day after end of plan year when modifica-tion was adopted

Plan Administrator Participants, Beneficiaries

7/31 Annual Report of Plan [5500 Series Filing]9

Form 8955-SAA (Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits)Filed when there are terminated participants who have deferred vested account balances/accrued benefits.

Last day of 7th month beginning after end of plan year (or as extended)Last day of 7th month beginning after end of plan year (or as extended)

Plan Sponsor

Plan Sponsor

EBSA of DOL

IRS. The information is then shared with the Social Security Administration.

9/30 (or 12/15 with extension)

Summary Annual Report for defined contribu-tion plans. Defined benefit plans must provide Annual Funding Notice within 120 days follow-ing the plan year end (e.g., 4/30 for a calendar year plan).

Last day of 9th month beginning after end of plan year (or as extended)

Plan Administrator Participants, Beneficiaries

10/3 – 12/2 Safe Harbor Plan Notice, Qualified Automatic Contribution Arrangement (QACA) Notice

30-90 days prior to start of plan year using S.H. or QACA design

Plan Administrator or Plan Sponsor

Participants

10/15 Extended Form 5500 Filing Deadline (Form 5558 must be timely filed)Extended Form 8955-SSA Filing Deadline (Form 5558 must be timely filed)

2 ½ months after initial filing deadline

2 ½ months after initial filing deadline

Plan Sponsor

Plan Sponsor

DOL

IRS

12/2 Automatic Enrollment Notice Eligible Automatic Contribution Arrangement (EACA)

30 days prior to the beginning of the plan year Plan Administrator Participants

12/2 Qualified Default Investment Alternative (QDIA) Notice

Annually at least 30 days prior to the beginning of the plan year

Plan Administrator Participants

11/2 – 12/2 SIMPLE Plan Notice 30-60 days prior to the start of the plan year Plan Administrator or Plan Sponsor

Participants

12/31 Corrective Distribution for Failed ADP/ACP with 10% Excise Tax or QNEC Distribution

Last day of plan year following the year of failure

Plan Sponsor or Plan Administrator

Participants or Trustee

Each pay-period Deferral Remittance and employee after-tax contributions

As soon as administratively possible, not to exceed 15 business days after end of month remittance was taken10

Employer Trust/Custodian, Recordkeeper

Depends on when the plan imposes a temporary suspension, limitation or restriction on the ability of participants to direct or diversify assets, obtain loans or take distributions.

Black Out Notice (defined contribution) 30-60 days prior to last day in which participant may effect change

Plan Administrator Participant, Employer (if publicly traded company stock is involved)

D E A D L I N E F O R 4 0 1 ( K ) P L A N S

401(k) Plan Actual Deferral Percentage Test (ADP Test)* 401(m) Plan Actual Contribution Percentage Test (ACP Test)If the ADP/ACP of your NHCE group is: The ADP/ACP of your HCE group cannot exceed:

Under 2% of compensation 2 times the rate of the NHCE Group compensation

Between 2% and 8% 2% more than the rate of the NHCE Group of compensation

Over 8% compensation 1.25 times the rate of the NHCE Group

Note: ADP Test deemed satisfied for Safe Harbor 401(k) plans. The ACP Test for a Safe Harbor plan is deemed satisfied if certain conditions are met. If these are not met, then the Safe Harbor plan must pass the ACP Test. * ADP Test not required for 403(b) plans and/or 457 governmental plans

I N D E X E D R E T I R E M E N T P L A N L I M I TAT I O N S

2016 2017 2018 2019 2020

Section 415 Defined Benefit Annual Limit Monthly Limit

$210,000 $17,500

$215,000 $17,916.67

$220,000 $18,333.33

$225, 000 $18,750

$230,000 $19,166.67

Section 415 Defined Contribution Dollar Limit* $53,000 $54,000 $55.000 $56,000 $57,000

Employee Salary Deferral 401(k) Plan/SARSEP SIMPLE IRA/ SIMPLE 401(k)

$18,000

$12,500

$18,000

$12,500

$18,500

$12,500

$19,000

$13,000

$19,500

$13,500

401(k) Catch-up Simple Catch-up

$6,000 $3,000

$6,000 $3,000 $6,000 $6,000 $6,500

Minimum Compensation $600 $600 $600 $600 $600

Maximum Compensation $265,000 $270,000 $275,000 $280,000 $285,000

Taxable Wage Base OASDI @ 6.20% rate HI @ 1.45% rate**

$118,500 unlimited

$127,200 unlimited

$128,400 unlimited

$132,900 unlimited

$137,700 unlimited

Note: 1987 is the base year upon which the annual cost of living changes have been made. * Generally, a participant in a 403(b) plan need not aggregate contributions made thereunder with contributions to a qualified plan for purposes

of the Section 415 limit.** This 1.45% rate does not reflect the additional 0.9 percent in Medicare taxes certain high-income taxpayers are required to pay.

© 2020 Massachusetts Mutual Life Insurance Company (MassMutual®), Springfield, MA 01111-0001. All rights reserved. www.MassMutual.com.RM2604 320 C:RS-01801-16 4/1/21