The SPD regs say that the SPD must accurately reflect the provisions of the plan as of a date not earlier than 120 days prior to the date the SPD is disclosed. As long as there are no intervening plan amendments, is it acceptable to put an "effective date" in the SPD that's more than 120 days prior to distribution?

Example: Healthcare plan last amended effective January 1, 2004. Revised SPD in progress, to be distributed July 2004. Language on front page says, "This booklet reflects plan provisions as of ____." Can blank be completed as "January 1, 2004" or does it have to be a date within 4 months of July?