Top Hat plans are unfunded plans for a select group of management or highly compensated employees. Section 2520.104-23 of the Department of Labor's regulations requires that plan sponsors file ďa statement with the Secretary of Labor that includes the name and address of the employer, the employer identification number (EIN) assigned by the Internal Revenue Service, a declaration that the employer maintains a plan or plans primarily for the purpose of providing deferred compensation for a select group of management or highly compensated employees, and a statement of the number of such plans and the number of employees in each.Ē
Below are electronic filing instructions for the DOL Top Hat Plan and Delinquent Filers Voluntary Compliance Program, and a searchable database of existing Top Hat filings.
Top Hat Filing Database
Pangburn offers a searchable database of the Department of Laborís Top Hat Letter filings. The database search tool is generally updated during Q1 of each year through the prior calendar year end. Users may search by company name or zipcode. A full listing of all filings by state is also available.
This data is provided for informational purposes only. It is based on information available to the public and acquired from the Department of Labor under the Freedom of Information Act. Pangburn does not guarantee or warranty any of data provided hereunder.