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11
Connecticut CPA
g
November/December 2014
Z
eisler
& Z
eisler
, P.C.
Workouts
Financial Restructurings
Bankruptcy
Commercial Transactions
Litigation
www.zeislaw.com
10 Middle Street, 15
th
Floor, Bridgeport, Connecticut
Contact: James Berman, Esq. jberman@zeislaw.com (203) 368-4234
Comprehensive Solutions for Your Client's Financial Challenges
paid advertisement
The name of the insurance com-
pany issuing the fidelity bond, but
only if the Plan is subject to the
special SPAW bonding require-
ments described above (i.e., if
< 95 percent of assets are Qualify-
ing Plan Assets);
A disclosure that Participants
can request copies of the docu-
mentation supporting the forego-
ing disclosures;
A disclosure that Participants
should contact the DOL if they are
unable to obtain this supporting
documentation.
Important Take-Aways
Small Plans that are completely
invested in Safe Harbor Individ-
ual Accounts have no additional
requirements under the revised
SPAW regulations.
All other plans at a minimum are
required to include additional
disclosures in the Summary An-
nual Report, even if they are in-
vested entirely in Qualifying
Plan Assets.
Be diligent about determining
whether or not the entity mailing
statements to Participants is the
same regulated financial institution
that is holding Plan Assets. This
represents the single most sub-
stantial source of non-compliance.
David M. Beck, CPA, QPA, ERPA is
Director Administration Services at
PASI, LLC (Pension Administrative
Services Inc.) in Farmington, where he
specializes in plan design and imple-
mentation as well as advanced com-
pliance testing. He can be reached at
860-284-6880 or dbeck@pasiusa.com.
Small Plans that are completely invested in Safe Harbor Individual Accounts
have no additional requirements under the revised SPAW regulations.