IRS posts FAQ regarding deferred vested benefit statement

The IRS has a long standing requirement to provided a benefit statement to participants who terminated and were reported on the Schedule SSA attached to the Form 5500.  The Schedule SSA has been replaced by Form 8955-SSA which requires plan sponsors to indicate whether or not the statement was provided to the participant (question 8).  There has been a flurry of discussions regarding how plan sponsors should answer that question.  The new FAQ should provide some comfort to plan sponsors and is reproduced below.

What are the requirements for answering “yes” to question 8 on Form 8955-SSA? Question 8 on Form 8955-SSA asks whether the plan administrator provided an individual statement to each participant required to receive a statement. The instructions to the Form add that the plan administrator must, before the expiration of the time for the filing of the Form, furnish to each affected participant a statement setting forth the information required to be contained in the Form. May the plan administrator satisfy this requirement by using other notices such as benefit statements and distribution forms? Also, does this mean that the plan administrator must furnish a notice that includes all of the information on the Form 8955-SSA? A plan administrator may answer “yes” to question 8 if the required information was timely furnished to participants in other documentation such as benefit statements or distribution forms. A separate statement designed specifically to satisfy this requirement is not required.  A plan administrator may answer “yes” to Question 8 if the statements or other documentation issued to the participants include the following information: Name of the plan Name and address of the plan administrator Name of the participant Nature, amount, and form of the deferred vested benefit to which such participant is entitled. Thus, for purposes of completing Form 8955-SSA, the plan administrator’s notice to the plan participant does not need to include the participant’s social security number, the codes on page 2 of the Form 8955-SSA used to identify previously reported participants, or any information regarding any benefits which are forfeitable if the participant dies before a certain date.