Christine Roberts Posted August 16, 2002 Posted August 16, 2002 The preamble to the DOL regulations on SPD contents issued in Nov., 2000 state that existing disclosure rules require "a reasonably comprehensive and clear description of the provisions of a cash balance plan and how a prior conversion may have affected benefits that classes of participants may have reasonably expected the plan to provide." 65 Fed. Reg. at 70227. Is anyone making SPD disclosures of this nature? If so, is it only in the case of recent conversions? What about a conversion that took place over 10 years ago? Comments appreciated.
IRC401 Posted August 17, 2002 Posted August 17, 2002 Did the sponsor comply with 204(h)? [i happen to think that suing over the failure to give 204(h) notices will be a lucrative product line for plaintiff's attorneys]. Did the sponsor ever issue an SPD that explained how the conversion worked ?
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