DVFC

[Guest cease]

I have a question about the DFVC process. I understand what forms have to be completed and sent to EBSA, but I am unclear with what needs to be done with the SAR.

If a 5500 (for a H&W) plan was never filed (calendar year effective 01/01/95) and as a result, the SAR was never distributed to participants, what is the requirement 8 year later? Unless I am blind, I did not see mention made of this in the rules and regulations related to DFVC, the FAQs on the DOL website, or by revewing posts in BenefitsLink.

Is the failure to distribute the SAR covered under the DVFC program?

Does the plan sponsor need to recreate who should have received the SAR for the filing years in question?

Any advice on this issue would be greatly appreciated.

Thanks.