| Summary Annual Report
1. Are there any text changes to the Summary Annual Report format?
Yes, but the changes are very minor. Check the latest regulations issued by Department of Labor on April 19, 2000 and June 5, 2000 [see DOL's website or http://www.benefitslink.com/].
2. Must a Summary Annual Report be provided to each participant or can it be posted in a conspicuous location at the employer's business?
ERISA Section 104(b)(3) requires the Summary Annual Report to be furnished to each participant; therefore, a plan sponsor cannot meet the requirement by just posting the statement on a bulletin board or near the water cooler.
3. A calendar year plan pays a terminated participant on January 15, 2001. Must that participant receive a copy of the plan's Summary Annual Report for the period ending December 31, 2000?
There appears to be no exception provided in the regulations. As a practical matter, this former participant will probably not spend any time reading the report but it must be provided to them anyway.
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