Michael A. Webb, Vice President, Retirement Plan Services, Cammack LaRhette Consulting, answers:
Technically, Summary Annual Reports, or SARs have always been required for 403(b) plans that are subject to ERISA. However, the confusion is understandable and the requirement was difficult to administer in practice, since the SAR is a summary of information contained on Form 5500, and historically there was virtually no information provided by 403(b) plans on their 5500 forms. However, the new 5500 requirements, effective with the 2009 plan year, changed all of that. 403(b) 5500s will now contain a wealth of information, so the Summary Annual Report may be a more meaningful disclosure, much as it has been for qualified plans such as 401(k) plans.
A properly drafted SAR will include all of the following information:
1) administrative expenses incurred by the plan;
2) amount of benefits paid to participants and beneficiaries;
3) total value of plan assets; and
4) notice of right to receive a copy of the full annual report, or any part thereof.
The SAR must be provided to all plan participants nine months after the conclusion of the plan year (September 30th of each year for calendar year plans), or two months following the due date of the Form 5500 if an extension has been granted by the IRS (December 15th for calendar year plans).
Complete filing details, including a sample report, are here.
NOTE: This feature is to provide general information only, does not constitute legal advice, and cannot be used or substituted for legal or tax advice.
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