I have a small plan for which I am doing the alternative reporting. There was a distribution in 2008.

The instructions say for the alternative reporting regarding Schedule R (p.9 of instructions): Identifying information and Part II. If I have nothing to report in Part II, do I still have to file it?

The instructions under the Voluntary Alternative Reporting Option state that you should file the schedules that are applicable. Schedule R itself says Part II should be skipped if the plan is not subject to IRC Sec. 412 of ERISA Sec. 302. So if the plan can skip Part II then the way I see it Schedule R is not required to be filed.

However, it is not going to be a huge effort if 5500 software is used to file Schedule R with only the identifying information.

But, if we file that Schedule R (with only identifying information), will the IRS notice the abbreviated Schedule A and no Schedule D?