SAR to Include or Not Include the Paperwork Reduction Act Blurb?

Hello. The DOL template for the SAR for welfare and pension plans includes the two-paragraph blurb on the Paperwork Reduction Act. However, in another location on the DOL website, there is instruction not to include the blurb. I called the DOL Office of the Chief Accountant to confirm which way to approach and they have to do research. Does anyone have advice on which way to approach? Many thanks! 

If one reads the Paperwork Reduction Act Statement, one strains to imagine how its text could impart useful information to a participant, beneficiary, or alternate payee.

A plan’s administrator might be amused by: “The public reporting burden for this collection of information is estimated to average less than one minute per notice (approximately 3 hours and 11 minutes per plan).” But it would be an extraordinary participant who might file with the Labor department a comment on the administrator’s burden. And how would a participant know how much time it takes for an administrator to assemble a summary annual report? https://www.dol.gov/agencies/ebsa/employers-and-advisers/plan-administration-and-compliance/retirement

This is not advice to anyone.

On 7/1/2024 at 12:55 PM, 5500Nerd said:

Hello. The DOL template for the SAR for welfare and pension plans includes the two-paragraph blurb on the Paperwork Reduction Act. However, in another location on the DOL website, there is instruction not to include the blurb. I called the DOL Office of the Chief Accountant to confirm which way to approach and they have to do research. Does anyone have advice on which way to approach? Many thanks! 

Where do you see the DOL template that includes the blurb? 

The hyperlink in my post points to sets of forms and notices, including two models for a summary annual report.

Hi Everyone, I have an update for you. I spoke to the Office of Regulations and Interpretations of the DOL. They model notice has the Paperwork Reduction Act because this information needs to be seen by the Plan Sponsor/ the Employer. However it does not need to be in place for the participants. The employer can remove if they choose.