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Summary Annual Report for Calendar Year Plans Due 9/30

The Summary Annual Report (SAR) must be given to plan participants within 9 months of the end of the plan year if the employer had to file Form 5500. For calendar year plans, this means it must be given out by September 30th. If a 5500 extension was filed, the employer must send the SAR within 2 months after the close of the period for which the extension was granted.  

For example, a calendar year plan has to distribute the SAR to participants for the 2018 plan year by September 30, 2019. But if the plan applied for an extension to the Form 5500 filing, the SAR is then due within 2 months after the filing.

Under ERISA, a “participant” is “any employee or former employee of an employer…who is or may become eligible to receive a benefit of any type from an employee benefit plan which covers employees of such employer…or whose beneficiaries may be eligible to receive any such benefit.” In other words, only employees (not dependents or spouses), COBRA qualified beneficiaries and any enrolled retirees must be provided a SAR.

Note that there’s an exemption from having to distribute a SAR for plans that don’t have to file Form 5500, and for totally unfunded self-insured plans, regardless of size. As a reminder, “unfunded” means that the employer plan sponsor pays benefits out of general assets and not from a trust. This is true even though large unfunded plans (with 100 or more participants) must file Form 5500. However, large fully-insured plans are subject to the requirement to give out the SAR.

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