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What to provide participants as part of a "full annual report&quo


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Posted

Our summary annual report tells a participant that they are entitled to receive a copy of the "full annual report". I am saying that this refers to a copy of the complete Form 5500 and related schedules, excluding the SSA. I'd like to know what others are providing to participants in response to this question.

Posted

That is my understanding of that phrase. Don't forget that the auditor's report is included in the definition of "related schedules", if applicable.

Even though the sponsor can charge a "copying cost" for this, certain parts must be provided without charge, that is the asset pages of the 5500.

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

Posted

It is my understanding that instead of providing the participant with a Summary Annual Report, the plan sponsor can provide the entire 5500C (with schedules).

Since starting in 2000, we have new 5500s (which are not the most readable), I wonder if any plan sponsors will be providing participants with the new 5500s rather than SARs.

I am bringing this up because, under proposed DoL regulations (I think), the SAR has to include additional information in order to avoid the requirement that a plan with fewer than 100 participants obtain an audit.

Posted

Forms / schedules that have "This Form is Open to Public Inspection" in the upper right corner are the ones that the employee can have a copy of.

The SSA has confidential information such as SSN and account balance. Therefore, "This Form is NOT Open to Public Inspection" and you should not distribute.

Posted

ERISA Section 104(B)(3). Note cross reference to sec 103(B)(3).

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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