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Severance Pay Plan as a Welfare Plan

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My understanding that a severance pay plan that is filed as a welfare plan need only complete Form 5500.

Schedule As are not required since there are no insurance providers. Schedule C and Schedule H are also not required.

The severance plan assets, in this plan, remain a part of the general assets of the company (no Trust).

My question is:

Is a Summary Annual Report required to be distributed to employees or would a severance plan be exempt from the SAR?

Since there are no Schedule As, Schedule C, Schedule H, the financial information would not flow through to a SAR which would make it appear inaccurate.

Thank You

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