SAR/AFN Requirement for Retroactively Adopted Plans

[rbates]

If we do not file a 2021 Form 5500 for a plan adopted after year-end, is the Plan still required to distribute an AFN or SAR (whichever applies) to Participants ? It wouldn't make sense to distribute a summary of a 5500 that isn't being filed, but I haven't seen this addressed specifically.

[CuseFan]

The SAR due date is specifically tied to the due date of the 5500, is it not? As there is no due date for a 2021 5500 filing as a filing is not required, I think that necessarily means there is no due date for a 2021 SAR and one is not required.

The AFN due date is tied to the plan year, correct? So I'm not sure if you have a 2021 get of jail free card on that notice if otherwise required, but I'm not involved in administration at that level.