SAR for 2-participant plan

[SMB]

I have some 2 and 3-participant DC plans and have a real problem with the SAR requirement - especially when the investments are participant-directed.

Obviously, it's fairly easy for employees in such situations to figure out the amount of the business owner's plan account (and, potentially, his/her salary) - information which in definitely not "open to public inspection"!

Has anyone else out there grappled with this "privacy" versus (relatively meaningless) "disclosure" issue? Has anyone ever seen/heard the DOL comment on the issue?

Thanks for any and all input!

[KIP KRAUS]

Never been in that cituation, but keep in mind that each plan participant can ask for an recieve a copy of the the complete 5500-C filing and still get the same information.

[pmacduff]

Wanted to put in my 2 cents...Depending on the business...if an office is that small (2 or 3 employees/participants) I think that everyone in the office pretty much already "knows the score". It's hard to keep things hidden in that type of environment. Also, if an employer is that suspicious of his 2 or 3 employees that they would make an issue of knowing his plan balance(s), perhaps he doesn't trust them and they should not be working for him! I think some credit has to be given the employees, they will probably be like the vast majority of the rest of us and file away their SAR when received not to be seen again for awhile, if ever.