1-person (+spouse) plan exceptions

For plans that file 5500-EZ, but have 2 participants, typically owner and spouse, and the plan has one 'pooled' trust, I'm thinking the following are not needed:

• List of Investments
• 8955-SSA (for retired spouse) - This was previously an attachment to regular 5500 and is filed with the IRS, so doesn't seem like it would be filed

To the first bullet, that just usually goes on the SAR.  But the SAR is not needed for EZ plans, right?

To the second:  are EZ plans subject to the vesting standards of ERISA 203?  From the 2021 8955-SSA instructions:

"Sponsors and administrators of government, church, and other plans that are not subject to the vesting standards of section 203 of ERISA (including plans that cover only owners and their spouses or cover only partners and their spouses) may elect to file Form 8955-SSA voluntarily."

(emphasis mine)

So, does this mean they MAY but don't HAVE to file one? 

(And why would you want to file one voluntarily?  And you don't even have to give all the info:  "If such a plan administrator so elects [to file voluntarily], the plan administrator is encouraged to provide as much information as possible, but no specific requirements are imposed."

12 minutes ago, BG5150 said:

To the first bullet, that just usually goes on the SAR.  But the SAR is not needed for EZ plans, right?

There is a list of assets "required" under PPA (very few do it, in part because the DOL never came out with regs that they were required to issue within 6 months...this was the PPA of 2006). Not the list of companies holding investments on the SAR.

14 minutes ago, BG5150 said:

So, does this mean they MAY but don't HAVE to file one? 

Yes.