PPA and reporting updated vesting

[Guest M. Martin]

In preparing for the new statement reporting requirements under PPA, have there been any changes in the frequency in which updated vesting must be reported? A model benefit statement is due to be released by the DOL but they have up to a year to make this available. Are practitioners considered to be acting in good faith until further directions are provided?

We operate in a daily environment and our plans receive participant quarterly statements as well as have access to their most current information online. For clients who only provide participant hours once a year their vesting is usually updated in time to be reflected on the 3/31 statements. Is there anything that requires vesting be updated more frequently than annually and (more importantly) in time for the 12/31/06 statements?

Thank you!