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Summary
Plan Descriptions
(Employee
Benefit Booklets)
Are your company's Summary Plan Descriptions
(SPDs) up to date? Do your Summary Plan Descriptions comply with the most
current rules as updated by recent Employee Retirement Income Security Act of
1974 (ERISA) requirements and other federal legislation?
Summary Plan
Descriptions must describe an employee's rights and obligations under his or her
benefit plan in a fair and unbiased manner. Do your SPD's? Are your Summary Plan
Descriptions written clearly, concisely, and accurately?
Labor Department
regulations dictate when the Summary Plan Description must be distributed,
exactly what information must be contained in the Summary Plan Description, how
the text should be designed, and the penalties for not complying with the
regulations.
**See our Guide
to Preparing the Summary Plan Description for what must be
disclosed in your employee benefit booklets.**
Don't just
comply with these ERISA requirements for disclosure, turn disclosure into
communication!!
©R.H.
Wohl & Associates/In Plain English® is a management consulting firm specializing in communicating and improving the
flow of factual information. For more than 25 years, R.H. Wohl &
Associates/In Plain English® has assisted clients of every size and type,
publish clear, user-oriented information, and improve their business procedures,
employee communications, and customer responses.
 |
The
In Plain English®
Guide
to
Preparing
the
Summary
Plan Description
Ronald H. Wohl
CMC
©In
Plain English® R.H. Wohl
& Associates, Inc. |
Table of Contents
**No part of this document may be
reproduced in whole or in part, electronically or on paper or by any other way
or means without the written permission of the Copyright Holder. **
About
the Author…
Ronald
H. Wohl CMC
Mr. Wohl is
a Certified
Management
Consultant
and the founder, senior consultant, president and CEO of ©RH
Wohl & Associates, Inc./In
Plain English®. He has over 34 years of experience in business and
management communications. Mr. Wohl is in charge of marketing, sales, client
development and interaction, human factors design and project management for the
firm.
Mr. Wohl
specializes in improving the flow, character, quality, and consistency of
factual information within an organization and between the organization and its
managers, employees, customers, and stakeholders.
He evaluates and prepares management communications for business, government and
human resources. Mr. Wohl researches and advises clients on human resource
policy and procedures and provides guidance in many areas of personnel
management. Mr. Wohl also helps clients develop corporate administrative and
human resource manuals and employee handbooks in both print and electronic form.
Mr. Wohl advises clients on the
administration and communication of employee benefits. He specializes in the
writing of summary plan descriptions (employee benefit books), flexible benefit
communications, and plan administration manuals. He also helps clients write
corporate and credit policy, laws and regulations, computer and software
manuals, product instructions, and helps them design computer screens for more
effective user access to information. He conducts focus groups, group
facilitations, employee attitude surveys, and marketing research studies. In
addition, he consults frequently on the needs of micro-businesses.
Mr. Wohl was a national employee
communications consultant for the Wyatt Company (now Watson Wyatt Worldwide). As
Supervisor of Program Analysis and Information for the National Rural Electric
Cooperative Association in Washington, D.C., he developed and maintained the
employee benefit, administrative, and marketing communications for 40,000
employees at 1,000 member cooperatives. He also was the risk, employee benefits,
and payroll manager for Montgomery College, one of the largest community
colleges in the United States.
He is the co-author of the
"Employee Benefits Communication Edge", a newsletter published by
Commerce Clearing House and "The Employee Benefits Communication
Toolkit" published semi-annually by Commerce Clearing House. He is
also the author of two additional books and several articles on employee
communication, cost containment communications, and managing human resources. He
was on the editorial board of a major managed care resource magazine. He has
spoken widely on human resources, employee benefits communication, communication
of factual information, and regulation and requirements of micro-businesses
(home-based business, telecommuting and home offices).
He is the author of the management
practice of "Re-Humanizing the Business"—focusing on increasing
loyalty, productivity, and profitability through increasing employee
satisfaction and participation in the business.
He is a graduate of George Washington
University (applied psychological anthropology and accounting), Mr. Wohl
attended the George Washington University Law School, American University School
of Business (MBA program), the Kemper Insurance Institute for Risk Management,
and Florida State University. He is listed in Who's Who in the United States
and other national and international publications. Mr. Wohl is a member of the
International Association of Business Communication and the Institution of
Management. He subscribes to the Code of Ethics of the Institution of Management
Consultants.
Back
to the Top
Introduction
Summary plan descriptions are the
most important communications employees receive from their employer describing
their employee benefit plans. Summary Plan Descriptions have a big job. They
must be accurate and comprehensive and unambiguous. Summary Plan Descriptions
must describe the benefits in a neutral manner without promoting one benefit or
procedure over another or minimizing the importance of one negative feature over
another. And Summary Plan Descriptions SPD's must be clear and easy to use by
employees.
The original rule requiring employers
to prepare SPD's for the benefit plan participants and beneficiaries was
announced in 1977. The rules governing what they must contain have grown
dramatically over the years. Recent proposed changes to these regulations
affect:
Claims procedures and response times,
Maternity stays in a hospital,
Mastectomy surgery,
Qualified Domestic Relations Orders,
Qualified Medical Child Support Orders,
Change in status, and
Pre-existing conditions
Provisions of investment information
these and other rule changes made in
recent years have had/and continue to have profound effects on what a Summary
Plan Description must describe.
Employers must continually consider
rewriting their SPDs to conform to the new requirements. Otherwise, Summaries of
Material Modifications (SMM) will become too numerous and the SPD will become a
collection of memos. Participants and beneficiaries will not learn what they
should know and not value their benefits as mush as they should.
One of the most significant changes
has been the response of the government to new technology. The Health Insurance
Portability and Accountability Act (HIPAA) permits health care plan summary plan
descriptions to be published electronically. While no other type of summary plan
descriptions are directly referenced, many plan administrators are looking at
the tremendous cost savings and communications advantages of Web-based
technologies for all their benefit plans.
This Guide is
based on the interim and proposed SPD Content regulations as of January 22,
2001.
After reviewing this Guide, let us
know what additional information you think SPD readers should receive in their
SPD. We are also interested in your opinion on the following:
How can the SPD be more useful to employees?
How can it be more effective?
How can reader interest be increased in both the print and electronic versions
of the SPD's?
What can be done to enhance the value of the SPD to the employer?
Send your response to:
In Plain English
PO Box 3300
Gaithersburg, MD 20885-3300
Or by e-mail to:
rwohl@inplainenglish.com
Back
to the Top
Summary
Plan Descriptions
(Employee
Benefit Booklets)
Summary
Plan
Descriptions
(SPDs) are employee benefit descriptions required by the Employee Retirement
Income Security Act of 1974 (ERISA).
These plan summaries must describe an employee's rights and obligations under
his or her benefit plan in Plain English, and in a fair and unbiased manner.
Labor Department regulations dictate when the SPD must be distributed, exactly
what information must be contained in it, how the text should be designed, and
the penalties for not complying with the regulations. Just complying with these
regulations will meet ERISA requirements for disclosure. But, disclosure does
not mean employees will readily understand their benefits, or how to use them
more effectively or efficiently — to do that, is communication.
Turning
disclosure into communication requires
careful analysis of:
The
benefit plan documents
How
benefits are administered
Who
will read the information
Many different audiences may read the
SPD, each having a specific purpose in mind. These audiences not only include
employees and their families, but human resource and benefit administrators,
benefit providers, claims adjusters, lawyers, judges, juries, the press, and
many others. Benefit information must be described sufficiently to be understood
by each group in the same way. In addition, the SPD must be equally clear to
employees of different cultures and levels of education, as well as those of
different ages, lifestyles, and life stages.
What is said in
the SPD must take into consideration many factors besides legal requirements:
How
employees think about their benefits
Employee
logic and reading comprehension levels
Difficult
to understand benefit provisions
Sensitive
administrative and labor issues
The
purpose and strategic goals of the company's employee benefit philosophy
At In
Plain
English®,
we believe that the summary plan description should be a clear, concise, correct
and jargon-free guide for employees to learn about their benefits, as well as
for the plan administrator to use to pay claims for benefits.
Employees read about their benefits
when they need them and often when they are under stress. They
need to have a successful first use of the SPD, or they may never
refer to it again. Typical
insurance company-provided employee certificates, evidences of coverage, or
"off the shelf" SPDs do not fully meet employee needs for adequate and
worthwhile benefit communication.
Summary Plan
Descriptions prepared by In Plain English®
are custom prepared and specifically written for each client's benefits,
objectives, and requirements.
In
Plain
English®
is a full service, employee
benefit and human resources communication firm. Since 1977, we have been helping
our clients meet government requirements and "turn disclosure into
communication." In
Plain
English®
specializes in determining the precise audience's) for specific communications,
getting into the audience's shoes, and writing and producing summary plan
descriptions and other benefit communications employees logically and clearly
understand and use.
In
Plain
English®
believes that it is important to your project's ultimate success that you be
comfortable with our editorial services. Consequently our
services are provided on a fixed fee basis.
This approach encourages client participation and questions. We work with you to
sharpen the message and text until it is readily usable by your employees.
"Our
Guarantee"
In
Plain
English®
will
make all the changes you and your plan's legal counsel and other advisors
require to bring the Summary Plan Description into full compliance with your
plan document at no additional cost. We document each paragraph of our first
draft so you can see what we used as the basis for our interpretation of your
plan. We guarantee client satisfaction with our editorial product or we will
rewrite the Summary Plan Description at no additional cost. We meet our
deadlines.
In addition to writing summary plan
descriptions, In
Plain
English®
designs and produces the finished product, including developing the document's
page layout, packaging, cover design and electronic posting in order to enhance
the information's readability and usefulness. We can also print and produce the
final copies for distribution, while being ever mindful of your benefit
communication budget.
In
Plain
English®
also prepares print and electronic highlights brochures, flex-benefit
communications, orientation programs, employee handbooks, training materials,
audio-visual presentations, and newsletters.
Back
to the Top
Legal
Requirements for
Benefit
Communications
Summary
Plan Descriptions
Summary
plan descriptions (SPDs) which are mandated by ERISA (The Employee Retirement
Income Security Act of 1974, as amended).
They are the fundamental employee benefit communication employees receive from
their employer. SPDs have a big
job. They must describe the benefit
plans they represent in a clear and comprehensive manner.
They also must describe the facts and procedures of a plan in a neutral
manner, without promoting one benefit or procedure over another or minimizing
the importance of any features.
In
1998, the federal government recognized the need to allow employers to adapt
their communications to the intranet. The Health Insurance Portability and
Accountability Act (HIPAA) was extended in 1998 to permit health care plan SPDs
to be published electronically (ESPDs).
In January 1999, the U.S. Department of Labor Office of Pension and
Welfare Benefit Plans announced proposed and interim rules to permit all other
types of SPDs to be prepared for electronic distribution to participants and
beneficiaries.
This
guide outlines what each SPD is required to contain to meet federal requirements
for disclosure to plan participants and beneficiaries. These requirements
include those for electronic summary plan descriptions (ESPDs). Each compliance
issue is organized into a series of questions and answers to provide both a
logical print version and electronic version for use by your company.
Please note:
The following is meant to be a
guide to those benefit plan administrators who are interested in producing their
company’s summary plan descriptions (SPDs) for their employees or who want to
be more effective managers of those internal or external resources who are given
the assignment to prepare the SPDs and other benefit communications. This
guide is not meant to replace competent legal advice from your plan advisor.
The information contained here is based on current, proposed and final
regulations as issued by the Department of Labor as of
November 22, 2001.
How
to Write Summary Plan Descriptions:
Language and Style
The
Summary Plan Description must describe the benefit plan in a manner that is: “calculated
to be understood by the average plan participant and shall
be sufficiently comprehensive to apprise the plan’s participants and
beneficiaries of their rights and obligations under the plan.”
Make sure the language is consistent throughout the SPD.
Present information in a single “voice” or style.
-
Consider
your employees’ level of comprehension and education, and the technical
complexity of the plan.
-
Eliminate
jargon, as well as long, complex sentences.
-
Do
not emphasize or promote any feature or minimize the importance of any part of
the description.
Do not leave out any required information or in any way mislead or
misinform participants and beneficiaries.
-
Place
the following disclaimers prominently at the beginning of the SPD:
—"Although the SPD is a
summary of the official Plan Document and is not the official Plan Document
itself, a number of courts have held that the SPD is the document employees can
rely on."
Employees should be told to "see the Official Plan Document for more
detailed descriptions of Plan rules and procedures and that if there is an
inadvertent difference in meaning between the language in the SPD and the plan
document, the language in the plan document will govern because it is the
official document governing the plan, while the SPD is only a summary."
—Participants and
beneficiaries should rely only on the
written information
describing the plan, not on any oral statements made about the plan.
—The SPD is
not a contract of employment, nor does it give any rights to a job or continued
employment.
—The plan
administrator and the plan trustees (if a trusteed plan) have the final
discretionary authority to interpret the plan.
—The plan sponsor has the right to amend or discontinue the plan at any time.
-
Where
separate SPDs
are prepared for members of different classes of participants or different
plants with different benefits, make sure that the first page of each SPD
identifies both the class or plant to which the SPD refers and the SPDs
describing the plans’ coverage of each other class or plant.
-
Summary
plan descriptions must be prepared and distributed to employees within 120
days after the effective date of a new plan, or the date that a plan first
becomes subject to ERISA disclosure requirements.
Employees must receive an SPD within 90 days of becoming a participant.
Beneficiaries must receive an SPD within 90 days of first receiving a
benefit.
A summary of material modification (SMM) to a plan or an updated SPD
must be issued 210 days after the adoption date of a material modification or
change to an existing plan.
An updated SPD must be issued every five years;
changes were made within that initial five years if any substantive changes
are made to the plan during that period.
-
If a material modification to a plan providing group health benefits
results in a reduction of benefits, the SMM for that plan must be provided
employees within 60 days after the modification or change is adopted. However, if the employer provides regular periodic
communications to employees at least every 90 days, such as a company
newsletter, the reduction may be communicated there, as well as directly to
employees, retirees and beneficiaries who do not receive that periodic
communication.
Foreign
Language Requirements
If a plan covers 100 or more participants, and at least 10%, or 500
participants, whichever is less, cannot comfortably understand written English
but are literate in the same non-English language, you must provide those
participants with an English language SPD bearing a statement that someone will
explain the plan and its rights and obligations to them in their language. This
statement must be printed prominently in that language on the first page of the
SPD. An SPD translated into that language would, of course, fully comply with
the regulation.
Care must be taken that translations are not only accurate, but that they
say the same thing in the same context as the English language version.
Translations that are “dictionary correct” generally do not convey
the same meaning as written translations by a native bilingual translator or
spoken translations by a native language interpreter.
Many languages have dialects that vary greatly from the official version
of the language. Someone familiar
with only a dialect version of his or her own native language will have a
difficult time understanding a description of his or her employee benefits
presented in either a different dialect of their native language or in the
official version of that language.
For
example, Spanish has at least five different dialects plus the official version
of Spanish called Castilian. Certain
English terms such as “coverage,” “blanket,” and “umbrella,”
translate very differently in each dialect.
To remedy this translation problem, start with an original English version
written in clear, conversational, plain English.
Have a bilingual translator, literate in the dialect of the majority of
your non-English literate employees, translate the SPD into that language and
dialect. It is beneficial to
identify at least one individual in each foreign language group of non-English
literate employees, who could translate from English into that language.
This will enable you to better communicate your benefit communications as
well as your human resources, safety, and other programs; and allow you to
effectively communicate with non-English speaking employees.
Translation software programs may help in the translation process.
However, all translations should be checked by a native speaker of the
dialect to ensure that the translation is correct and does not sound funny when
employees read or listen to it. Keep
in mind that the translation represents your best efforts at communicating in
the minds of your employees. Moreover,
it should be just as clear and understandable to those employees as your best
efforts at English based communications will be.
Listed
below are foreign language sentences that should appear on your first page of
the Summary Plan Description if you meet the requirement to provide the
bilingual translation.
"If you do not read or understand English, please contact the Human
Resource office and they will provide you with someone who will explain the
information in this booklet in a language you do understand."
Requirements
for Electronic Summary Plan Descriptions (ESPDs)
You may provide summary plan descriptions electronically if the following
conditions are met:
—You must take appropriate steps
to ensure that participants actually receive the electronically transmitted
information. This may be done by using a return receipt electronic mail feature
or by conducting periodic reviews or surveys to confirm the integrity of the
delivery system.
—The electronic disclosure must be
consistent with the style, format, and content requirements that would apply to
a paper disclosure of the same information.
—The document must qualify as an
SPD.
—The document must contain summary
descriptions of changes in the benefits described in the SPD.
—Each participant must be able to
access electronic documents at his or her worksite and readily receive
printed-paper versions at no charge at his or her worksite.
—You must notify each participant
(through electronic or other means) of the type of
documents and the significance of those documents that are being electronically
disclosed.
—You must provide a free paper
copy of each document upon a participant’s request.
Assure that print versions of an electronic SPD contain all the
information needed to meet the SPD requirements.
What
Content Must Appear In The Summary Plan Description
The
information required to appear in summary plan descriptions is divided into
three categories:
·
What must appear in all SPDs
·
What must appear in pension plan SPDs
·
What must appear in welfare plan SPDs
These
regulations recognize the differences between collectively bargained plans and
those that are not covered by collective bargaining agreements.
They also recognize that there are differences between the types of
benefit plans within a category.
Not
all content requirements come from the Employee Retirement Income Security Act.
Some required content comes from other federal laws and regulations.
While many of these have been incorporated into ERISA, some have not.
For
example, the requirements for electronic transmission of summary plan
descriptions, originally introduced as a section of the Health Insurance
Portability and Protection Act (HIPPA), are now a subsection of ERISA at 29 CFR
2520.104(b) through 1(c) while other requirements affecting investment
information are governed by the Securities and Exchange Commission.
To
make these regulations easier to follow, we have divided the SPD content
regulations into two categories:
·
What must appear in pension plan SPDs
·
What must appear in welfare plan SPDs
and
have included the information required to appear in all SPDs into both
categories. Many of these regulations have been updated over the years.
On
November 21, 2000, the US Labor Department finalized the SPD content and
disclosure regulations and announced that they would go into effect on January
22, 2001. These revisions address virtually every aspect of the
disclosure regulations and will mean that most SPDs will need either to be
rewritten or supplemented with Summaries of Material Modifications in a
relatively short time. All
benefit plans need to be in compliance with these extensively revised
regulations by the second plan year beginning after January 22, 2000.
The citation to the legal background for each of these requirements is
shown so you can see it’s history.
The
content requirements that follow could change to reflect differing
interpretations of federal rules or additions or changes to regulations after
the publication of this book. Keep in mind, however, that the plan administrator
and plan sponsor are in no way relieved from their fiduciary responsibilities if
inaccurate or out-of-date information is included.
Back
to the Top
Pension
Plans
required
content and citation to federal regulations
|
Requirements
as of 11/21/00
|
Citation
|
Plan
Administration
|
|
|
Formal
name of the plan
|
29
CFR §2520.102-3 (a)
|
|
Informal
name of the plan
|
29
CFR §2520.102-3 (a)
|
|
Plan
sponsor name
|
29
CFR §2520.102-3 (b)
|
|
Plan
sponsor address
|
29
CFR §2520.102-3 (b)
|
|
Statement
that: A complete list of employers or
employee organizations sponsoring the plan may be obtained by a plan
participant or beneficiary upon written request to the plan administrator.
|
29
CFR §2520.102-3 (b) (3) (I)
29
CFR §2520.102-3 (b) (4) (I)
29
CFR §2520.104b-1 & 30
|
|
Statement
that: A participant or beneficiary may
request in writing to the plan administrator whether a particular employer is
a sponsor and if so their address.
|
29
CFR §2520.102-3 (b) (3) (ii)
29
CFR §2520.102-3 (b) (4) (ii)
29
CFR §2520.104-1 & 30
|
|
The
plan sponsor’s Employer Identification Number
The
plan number assigned by the plan sponsor
|
29
CFR §2520.102-3 (c)
29
CFR §2520.102-3 (c)
|
|
Information
required under a 404(3) plan:
§
Identification
of any designated investment managers.
§
An
explanation of the conditions under which participants may give investment
instructions and limits on such instructions, including:
-
Any restrictions
on transfers to or from an investment option
-
Any restrictions
on exercising voting, tender, and similar rights.
§
A
description of any purchase or sales fees and expenses that affect the
participant’s account balance (for example, commissions, sales load,
deferred sales charges, or redemption or exchange fees).
§
A
description of the information that participants can request from the plan
fiduciary, and the name, address, and phone number of the plan fiduciary
responsible for providing this information.
|
ERISA
§404 (c) (a)
|
|
§
For
plans that offer company stock:
-
A
description of the procedures for ensuring confidentiality of information
relating to a participant’s purchase, holding, and sale of employer stocks
and exercise of voting, tender and similar rights.
If the company stock is publicly traded, it must meet Rule 16b-3 and
provide Rule 144 information.
-
The
name, address, and phone number of the plan fiduciary responsible for
monitoring compliance with these procedures.
|
|
|
How
the plan is administered
|
29
CFR §2520.102-3(e)
|
|
Plan
administrator’s name
|
29
CFR §2520.102-3 (f)
|
|
Plan
administrator’s address
|
29
CFR §2520.102-3 (f)
|
|
Plan
administrator’s business telephone number
|
29
CFR §2520.102-3 (f)
|
|
Plan
year date
|
29
CFR §2520.102-3 (r)
|
|
Agent
to receive service of legal papers
|
29
CFR §2520.102-3 (g)
|
|
Legal
agent’s address
|
29
CFR §2520.102-3 (g)
|
|
Statement
that: Service of legal papers
(process) also may be made upon the plan administrator or a plan trustee.
|
29
CFR §2520.102-3 (g)
|
|
For
each plan trustee:
|
29
CFR §2520.102-3 (h)
|
|
Trustee’s
title
|
29
CFR §2520.102-3 (h)
|
|
Trustee’s
name & title
|
29
CFR §2520.102-3 (h)
|
|
Trustee's
principal place of business and address
|
|
|
For
a collectively-bargained plan:
|
29
CFR §2520.102-3 (i)
|
|
Statement
that: A copy of all collective
bargaining agreements regarding this plan may be obtained by participants and
beneficiaries through written request to a plan trustee or the plan
administrator.
|
29
CFR §2520.104b-8-30
|
Plan
Eligibility
|
|
|
Plan
requirements regarding eligibility to participate
|
29
CFR §2520.102-3(j)
|
|
Plan
requirements regarding eligibility for benefits
|
29
CFR §2520.102-3 (j)
|
|
Statement
describing plan’s Normal Retirement Age and any other conditions of
eligibility for benefits at normal, early, late, disability, or other
retirement, or termination.
|
29
CFR §2520.102-3 (j) (1)
|
Summary
of Benefits, Rights, and Obligations
|
|
|
Description
of plans benefits (summary) for current and future participants and
beneficiaries of the current plan.
|
29
CFR §2520.102-3 (j) (1)
|
|
Description
of the procedure for Qualified Domestic Relations Order (QRDO) determinations
or a statement that: Participants and beneficiaries can obtain a description of the
procedure for Qualified Domestic Relations Order (QDRO) determinations at no
charge from the Plan Administrator.
|
29
CFR §2520.102-3 (j) (1)
|
|
Definition
of compensation for each purpose used.
|
|
|
Statement
that: There is a 20% mandatory
withholding on all distributions or payments, other than distributions of
company stock, over the life (or life expectancy) of the employee and his or
her designated beneficiary.
|
Unemployment
Compensation Amendments Act of 1992 (UCA)
IRS
3405 (e) (8)
|
|
Description
of any joint and survivor benefits.
Description
of any election to select or reject the joint and survivor annuity and the
effect of each option.
Companies
that charge for the joint and survivor benefit are required to notify their
active employees between the first day of the plan year in which the employee
reaches age 32 and the end of the plan year in which s/he reaches age 34.
For an employee hired after age 32, the notice is not required until
one year after s\he becomes a participant.
The notice must explain the surviving spouse’s benefit, including
the spouse’s rights, the employee’s right to waive with spousal consent
and the effect of a waiver, and the employee’s right to revoke a waiver and
its effect.
|
29
CFR §2520.102-3(k)
|
|
Statement
clearly identifying circumstances which may result in disqualification,
denial, loss, forfeiture, or suspension of any benefits at normal, early,
late, disability, or other retirement, or termination, as well as upon
withdrawal from the plan or withdrawal of funds
|
29
CFR §2520.102-3(l)
|
|
Summary
of circumstances and plan provisions governing the authority of the plan
sponsors or others to terminate the plan, or amend or eliminate benefits.
Summary
of plan provisions governing benefits, rights, and obligations of plan
participants and beneficiaries on termination of the plan or amendment or
elimination of benefits, including for a pension plan:
§
Summary
of plan provisions relating to accrual and vesting of pension benefits on
plan termination.
§
Summary
of plan provisions governing allocation and
disposition of assets on termination.
|
29
CFR §2520.102-3 (m)
|
|
|