SMM Requirements as to content

[Belgarath]

Basically a ridiculous academic question, although I suppose it might have some applicability in the future for some sort of required amendment that pertains to all plans.

In these days of mostly pre-approved DC plans, suppose there is a required amendment, let's say something like the DOL disability regs or whatever, that is adopted by the document sponsor on behalf of all clients. It requires an SMM.

Is an SMM legally required to list the Plan and Employer name? Clearly the SPD must do this as per the DOL regs, under 2520.102-3. But I'm not certain that this specific requirement pertains to the SMM, as this information isn't changing - I didn't find, on a mid-level look, where it is specifically stated. Didn't use the fine-toothed comb. If not legally required, it could facilitate a "generic" mailing to all clients.

At best, I think it is foolish not to include plan and employer information, but is it ever an option not to? Curious as to any opinions on this.

[BG5150]

How can you provide a summary of changes to a plan if you do not indicate what plan it pertains to?

[Belgarath]

That was my assumption as well. But I do enjoy asking crazy questions sometimes.