One little noticed PPA requirement is the multiemployer summary plan report. It’s due to participating unions and contributing employers within 30 days after 5500 due date (starting with the 2008 5500), so one should have been filed already for most multiemployer pension plans.
The Department of Labor was required to publish a model form for by August 17, 2007, but has not yet done so. Until (or unless?) some guidance is released, plans will need to make a good faith effort to comply with this disclosure requirement.
