In the months of November and December, many of your clients will be issuing out various notices. For some, by December 15th, they will need to issue out the Summary Annual Report (SAR) for Plan Year 5500s that were under the October 16th extension. In addition, there are those who want to distribute the SPDs of the Wrap Plan Document. Both follow the same distribution rules. The checklist found below is an excellent guideline, outlining the general attributes for the distribution based upon ERISA’s participant disclosure requirements.
If you have any questions on our checklist, please feel free to contact Ann McAdam at email@example.com.
Special note: If the Wrap Plan Document has been amended within five years, the Plan Participants are to receive the Summary Material Modifications document (SMM) to attach to their SPD. The timeframes to meet are:
- 210 days after the end of the plan year in which the change is adopted
- No later than 60 days after the date of adoption if the change is a material reduction in covered services or benefit