Summary Annual Reports

[Guest T L Williamson]

I am looking for clarification of who to send Summary Annual Reports to. Everything I see says to send them to "plan participants and beneficiaries." Does this mean current plan participants, or participants as of 12/31/98? I assume as of 12/31/98, but can't find absolute verification of this. Also, what about someone who joined the Plan in April '98 and left the company in Sept '98. Should they get an SAR? These sounds like trivial questions but we have a large plan with hundreds of new enrollees and hundreds of terms each quarter...currently the plan is at least double the size it was as of 12/31/98. So the issue of who to send SARs to will affect hundreds and hundreds of people, and we want to be sure we know the correct procedure.

[John A]

T L,

I believe the DOL Regulations are ambiguous on this point. However, most TPAs I know use the last day of the plan year. In the final year of a plan, since ending participant count is zero, most TPAs I know believe an SAR is not required. However, none of this is based on either formal or informal guidance from the DOL or IRS, only on what I know practice has been. Does anyone know if this has ever been addressed informally at meetings with DOL officials?