ERISA 101(m) Diversification Noitce

[Randy Watson]

FAB 2006-3 essentially states that a Section 101(m) diversification notice is not required to be furnished if: (1) the plan provided diversification rights prior to 1/1/07 that were at least equal to those required under ERISA 204(j); and (2) the participants received quarterly benefit statements in 2007 that were PPA compliant. That first quarterly benefit statement would satisfy the diversification notice requirement.

Please tell me if I'm wrong, but I don't read the FAB to provide relief from furnishing the diversificaiton notice to participants entering the plan during or after 2007. That simply wouldn't make sense. Anyone agree, or disagree?