Notice to Terminated EA for Small Plan

[Guest mattr@qbcinc.com]

A Small Pension Plan changes actuaries. Per 5500 instructions, Schedule C is not required for a Small Pension Plan, but does the sponsor still need to send the notice to the Terminated EA as prescribed in the Schedule C instructions?

Seems to me, the answer here is "no." It might not have been in the same format as for a large plan where the Schedule C is required, but the prior EA is aware of the change. Is this good enough or do you think the prescribed notice should be sent, even if just to be on the safe side? I'm curious what others think or have done.

[WDIK]

I thought that the notice spoken of in the Schedule C instructions was to 1) inform the actuaries or accountants that information regarding them and the explanation of their termination was being disclosed on a form open to public inspection; and 2) give them an opportunity to respond to the DOL regarding the explanation.

If that is the case, it does not seem to me that a notice is required unless the Schedule C is filed.