Schedule A information. Automatic or on request

[Guest ak]

Is an insurance company, for a general account based contract (i.e., not a separate account), required to automatically provide information for the contract to be used on the Schedule A or does the information only need to be provided upon request? Statutory language (ERISA 103(a)(2)) and DOL 5500 instructions, etc. seem to indicate that it must be done automatically. But, DOL reg. 2520.103-5 seems to indicate that it only has to be provided upon request of the plan administrator. This language in the rules has been around for many years. Which approach is correct?