September 17, 2019
Plans that are subject to ERISA and Form 5500 filing must distribute the SAR to participants within nine months of the end of the plan year; thus, a calendar year plan is required to distribute the SAR for the 2018 plan year by September 30, 2019. If the plan applied for an extension to the Form 5500 filing, the SAR is then due within two months following that filing.
The SAR is a summary of the plan’s information reported on the Form 5500. If a plan is not subject to Form 5500 filing, then it is exempt from the SAR notice requirement — this would include church plans, governmental plans, and unfunded or insured plans with fewer than 100 participants. Also, large, unfunded self-insured plans are exempt from the SAR requirement even though they are subject to the Form 5500 filing requirement.
Model language is available for SAR preparation. Please ask your advisor for assistance. For additional information, see the frequently asked question featured in the August 23, 2016, edition of Compliance Corner.