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filing late under dfvcp and SAR's


Guest bruss
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We are filing several years of 5500's for a client who failed to file. We are filing under dfvcp. The question is, what about the SAR's that were never provided. Should they be provided now? Or just provide the current year to existing participants?

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We are filing several years of 5500's for a client who failed to file. We are filing under dfvcp. The question is, what about the SAR's that were never provided. Should they be provided now? Or just provide the current year to existing participants?

Provide them as soon as possibile.

...but then again, What Do I Know?

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We are filing several years of 5500's for a client who failed to file. We are filing under dfvcp. The question is, what about the SAR's that were never provided. Should they be provided now? Or just provide the current year to existing participants?

Provide them as soon as possibile.

Can you point me to any source or reference? thanks.

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  • 1 year later...
My opinion is based on the lack of any statement in the DOL's DFVCP Fact Sheet that removes the obligation to provide the SAR.

WDIK- I think that you're right, but to whom do I provide the SARs? Participants as of the date the SAR was due, or current participants? I've always been confused on this issue.

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  • 5 weeks later...
Guest Form5500Guru™

In general, ERISA and DOL regulations require that you provide the Summary Annual Report to the same categories of "participants" and "beneficiaries" you provide a Summary Plan Description. These categories are:

For Qualified Retirement Plans - You must provide the Summary Annual Report to each employee enrolled as a participant in the plan, and to each employee eligible to participate but not presently enrolled.

You do not have to provide a Summary Annual Report to an individual who has terminated participation or who is no longer eligible to participate, or to his or her beneficiaries. The one exception: any terminated participants for whom all annuity premiums due under the plan's provisions have not been paid at the time you distribute the Summary Annual Report. Consequently, you must send copies of the Summary Annual Report to these individuals.

In addition, you must provide a Summary Annual Report to former employees of institutions with supplemental retirement benefit arrangements, or other types of retirement plans (except unfunded plans for a select group of management or highly compensated employees) under which the participant or beneficiary must look to the institution or plan administrator for future benefits. Under such plans, if the participant is deceased and benefits are payable to a beneficiary, you should provide a Summary Annual Report to the beneficiary.

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