SAR completion under the new small plan disclosure requirement

[Guest Rudy]

I am completing my first SAR under the new small plan disclosure rules (plan year began after 4/17/2001). The instructions state that you must include the name of each regulated financial institution holding or issuing qualifying plan assets and the amount of such assets. The plan has numerous mutual funds issued by 6 mutual fund providers (Fidelity, Janus etc.). All the assets are held in a trust account with a local financial institution. How should this be disclosed?

Should each fund provider be listed once, with the total of all of their funds reported as one figure? Does the financial institution have to be listed if none of the assets are issued by it? I can see where to enter the information in the Relius program, but am unsure how to enter it.

I apologize if this subject has appeared here previously. With attention given to the restatement process, it has been quite a while since I last visited the message boards. Any guidance will be appreciated.

[jaemmons]

If the mutual funds are participant-directed investments and the plan record keeps individual accounts, no additional disclosure information is necessary in the SAR.

[kocak]

I'm confused on this topic as well. I thought that in order to be exempt from the audit requirement, a small plan filer had to meet the investment/bonding requirements AND the disclosure requirements.

For example, a plan that has at least 95% of qualifying plan assets doesn't need an additional bond, but still had to meet the disclosure requirements on the SAR.

Now if all the assets are in self-directed brokerage accounts, there is no disclosure, but if they are in a pooled trust, I thought I still had to disclose.

Any thoughts?

mck