I'm having a brain cramp. I remember that for small plans, there was an alternative to the long form SAR language in 2520.104b-10.

In lieu of preparing a full SAR, a Plan Administrator could distribute a notice that said a copy of the entire 5500 would be supplied on request. Another alternative was that a copy of the 5500 could be provided in full in lieu of preparing an SAR with the long form language.

I see that as late as 2007 TIAA-CREF was advising that these alternate approaches are still permissible. I just can't find the language in 2520.104b-10 anymore. Are my regs out of date, or is this small plan alternate rule to the full SAR in another location? Or, are these alternatives no longer available for small plans?

Thanks.

Back in the 5500 C/R days, I recall that C years called for an SAR and R years called for a Disclosure of Information (or something like that). When that ended though, it was SAR every year. I don't know of any shortcuts to this requirement.

[Back in the 5500 C/R days, I recall that C years called for an SAR and R years called for a Disclosure of Information (or something like that). When that ended though, it was SAR every year. I don't know of any shortcuts to this requirement.]

Thanks, but the ability to use a short form SAR rather than a full SAR was always tied into small plan / large plan distinction, not the old C & R cycle.

I am just surprised that TIAA-CREF would still be advising (in 2007) that the short form rather than full SAR is permissible for small plans. Look at page 4 and attachments #2 and #3 in this TIAA-CREF bulletin.

http://www.tiaa-cref.org/administrators/er..._403b_plans.pdf

You made me question my memory and go look it up. You are not correct. Here is a blurb I found:

5.Historical note: exception for Form 5500-C/R filer in pre-1999 plan years. An employer that filed Form 5500-C/R in pre-1999 plan years, using the "R" filing, could furnish a copy of the annual return in lieu of the SAR. See DOL Reg. §2520.104b-10(b). Alternatively, the administrator could furnish a written notice stating that a copy of the annual return could be obtained, without charge, by filing a written request for such copy. This notice could be posted on a bulletin board, if it was reasonably calculated to ensure disclosure to the plan participants. DOL Reg. §2520.104b-10, as amended on April 19, 2000, reflects the elimination of this exception.

Thanks, Blinky

Was TIAA-CREF giving incorrect advice on the ability to still use a short form SAR in every year?

I'm really surprised, because they are quite good usually on technical matters.