The preamble to the DOL regulations on SPD contents issued in Nov., 2000 state that existing disclosure rules require "a reasonably comprehensive and clear description of the provisions of a cash balance plan and how a prior conversion may have affected benefits that classes of participants may have reasonably expected the plan to provide." 65 Fed. Reg. at 70227.
Is anyone making SPD disclosures of this nature? If so, is it only in the case of recent conversions? What about a conversion that took place over 10 years ago?
Comments appreciated.