PPA Section 501 requires most single employer DB plans (covered by PBGC and greater than 100 participants) to distribute an annual funding notice to participants, beneficiaries and the PBGC no later than 120 days following the end of the plan year. For a 2008 calendar year plan, this would be 04/30/09. It is my understanding that this notice has been in place for multiemployer plans, but becomes effective for single employer plans for plan years beginning in 2008.

Can someone confirm that for a large DB plan that this 04/30/09 deadline still applies (i.e. there are no exceptions and no extensions)?

Can someone also confirm that model language has still not been issued by the DOL or IRS and the deadline of 04/30/09 is still in place?

Note: This is the notice that is supposed to replace the SAR for DB plans.

Thanks in advance.

I haven't seen any extensions, and according to SungardRelius, as of January 9, the DOL still had not provided a model notice.

Excellent timing. The DOL issued them today:

http://www.dol.gov/ebsa/regs/fab2009-1.html

The April 30th deadline is for all calendar year plans. If you need assistance with missing addresses or returned mail please let me know. We have a solution to meeting the impending April 30th deadline.

Would anyone happen to know if PPA section 501 (ERISA s. 101(f)) defines "participant?" That is, for purposes of distributing annual funding notices to participants are "participants" defined in either ERISA, the PPA or even the Code? I'm trying to find out if terminated unvested/terminated vested employees are required to receive the annual funding notice. Thanks!

See 101(f)(1).
Participant = active, retiree, beneficiary, VT, QDRO

Thank you. And thank you for the quick reply!