Small Plan Audit and SAR

[kocak]

I was under the impression that for a small plan filer to be exempt from an audit (PYB after 4/17/01) they had to meet the qualifying plan assets/bonding requirement AND the disclosure requirement.

However, reading Janice Wegesin's article in the ASPA Journal (May-Jun 2002) I get the impression they have to meet the qualifying plan assets OR bonding. If they meet the requirement by bonding, then disclosure on the SAR is needed.

I thought disclosure on the SAR was needed in any case, unless and exception (like all assets are participant-directed accounts) applies.

I'm looking at the DOL Reg and I'm not getting it. What am I missing?

michele

[Belgarath]

Agree that they must either meet the qualifying asset requirement, or increase their bonding as required. The SAR disclosure applies in either case.

[austin3515]

That's my impression as well, and I have ocnfirmed that with the DOL. I actually read the article you're talking about and had the same question!