403(b) non-ERISA matched with a SEP

How often do you see this combination - a non-ERISA deferral only 403(b), so no 5500's, and a non-IRS "prototype" SEP for the employer contributions, so no 5500's? Just curious.

By "matched with a SEP" in your title you mean paired with a SEP, not that matching contributions on 403(b) deferrals are made to the SEP, which would violate the uniform contribution requirement, right?

Haven't seen that before, interesting strategy to avoid government filings. 

You have obviously done your homework as the key to making this work is your reference to “non-IRS Prototype”.  You can’t do it with a 5305-SEP Form.  

Cuse - yes, "paired" with a SEP. It isn't a situation where the SEP contribution has anything whatsoever to do with 403(b) eligibility, deferrals, etc., etc. - it just exists completely independently.

Belgrath.... last comment critical.  "Paired with" makes us nervous because a Non-ERISA plan cannot be actually "paired with" anything or it will be ERISA.  But "paired with" means something in the "other plan" references or requires an action in the Non-ERISA plan.

Would this calm your nerves? The plans are maintained simultaneously. There is no language that "pairs" them.