5500Nerd Posted July 25, 2018 Posted July 25, 2018 Hello, We have several health and welfare plans that are unfunded - benefits paid solely from general assets with the exception of employee contributions. We have one attorney that declares that a SAR is not required because of Technical Release 92-01 - EE contributions if paid to the carrier within 3 months they are not plan assets. We have another attorney who disagrees and says that even with Tech. Release 92-01 the SAR is required because it is not funded 100% from general assets. I have not heard back from the DOL's Office of Regulations and Interpretations. Any thoughts if a SAR should or should not be issued? Many thanks for your consideration.
Madison71 Posted July 25, 2018 Posted July 25, 2018 My understanding is a totally unfunded H&W plan is not required to furnish an SAR. It is a specific exemption listed in the 104 regs.
5500Nerd Posted July 26, 2018 Author Posted July 26, 2018 Thank you! Question for you- if employee contributions are involved could the situation still be deemed unfunded (due to technical release 92-01)?
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