Schedule A information deadline?

[jkharvey]

We've been notified by one of the investment companies with insurance products that the information for schedule A is delayed YET again. Is there some legal requirement (DOL?) that requires this information be provided by a certain date? Something along the lines of deadlines for providing W2 or 1099 to employees and participants. TIA

[GMK]

ERISA Section 103(a)(2):

(a) General. In accordance with section 103(a)(2) of the Act, an insurance carrier or other organization which provides benefits under the plan or holds plan assets, a bank or similar institution which holds plan assets, or a plan sponsor shall transmit and certifty such information as needed by the administrator to file the annual report under section 104(a)(1) of the Act and Sec. 2520.104a-5 or Sec. 2520.104a-6:

(1) Within 9 months after the close of the plan year which begins in 1975 or September 30, 1976, whichever is later, and

(2) Within 120 days after the close of any plan year which begins after December 31, 1975.

I don't know if this has been amended.

I do know that the only period when we got Schedule A information within 120 days was during the recent downturn, when banks and insurers were under scrutiny. Prior to that, it took repeated requests into May or June, following the initial request in early January, to get the one page of numbers. Maybe we just happened to be dealing with the world's only unresponsive insurance company.

And just as reporting was getting more timely, we completed the elimination of investments that require Schedule A from our plan (yea!).