We have been waiting patiently for the final release of our 5500 software to go through. As it turns out, the very piece we have been waiting for will not be updated for 2003 on the software we use(!)

It is my understanding that the Summary Annual Report for small plans now needs to include the name of each institution holding plan assets, and the amount of the assets reported at each financial institution at the end of the plan year if the small plan is going to meet the requirements for an audit waiver.

Can anyone share a sample of the language in this statement as it appears on their 2003 SAR? I am going to have to input it manually on each of our clients' SARs. What fun.

Thanks.

Perhaps you are already ok. This requirement has been around since, (from memory) plan years beginning 4-18-01 and later. So maybe it is already written into the software you are using, and no specific update is necessary? If not, you may have failed to comply on a lot of prior filings...

The specific requirement to name each financial institution and specify the assets held at each institution is not new to 2003 . . . ?

Well, I can't sweat the past at the moment.

Is this language compliant?:

ADDITIONAL INFORMATION

The following institutions held or issued qualifying plan assets for the ____ Plan. As of December 31, 2003 these institutions reported the following amounts:

Institution 1 $amount
Institution 2 $amount

FYI-Our system says "The plan has met the requirements to waive the annual examination and report of an independent qualified public accountant. As of the end of the plan year, the following regulated financial institution(s) held or issued plan assets that qualified under the waiver."

Institution 1 $
Institution 2 $
etc

While true you are supposed to list the financial institution, don't forget, if the accounts are individual participant directed no such special language would be required.

However, even with individual accounts if participant statements come from a TPA rather than the financial institution itself you would not qualify. You may want to look at this link.


http://benefitslink.com/boards/index.php?showtopic=19647