RM 03258.010 Lag Period
A. Schedule SSA/Annual Registration Statement identifying separated participants with deferred vested benefits
Pension plans have up to 210 days after the close of their plan year (a plan may report on a fiscal year or calendar year basis) to file an Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits with the IRS. This report is filed whenever an “incident of separation” occurs i.e., individual permanently separates from covered employment OR has a break in service (individual leaves covered employment for a specified time) under a specific pension plan.
B. Processing times for the Schedule SSA/Annual Registration Statement identifying separated participants with deferred vested benefits
Approximate processing time of the report is seven months. Breakdown follows:
(Preliminary Examination and Forward to SSA)
(Examining and Scanning/Keying)
(Computer Update — Done on a quarterly basis)
The period between a participant's separation from employment and inclusion in SSA's deferred vested rights pension file could conceivably be as long a two years and two months. However, a more realistic period would be 15 to 18 months after the close of the plan year during which the “incident of separation” occurred.
Plan year ends
Report due IRS by (210 days)
IRS handles (60 days)
Recorded by SSA (150 days)
Total time lapsed – 26 months
Therefore, knowledge of the employment separation date is helpful when designating when a person should write back for pension information not yet on SSA records. SSA's experience indicates that the bulk of the reports are received by July and processed by December of the year subsequent to the end of the plan year in which the “incident of separation” occurs.
A general guideline is to have the individual write back in 15 to 18 months after the close of the plan year in which the “incident of separation” occurred. For example, if the individual leaves employment in 2008, advise him or her to write back in April 2010.
NOTE: Deferred vested benefit rights information is reported to IRS by a pension plan only after a plan participant separated from employment under the plan. If an individual has had an “incident of separation,” a report from the plan may be forthcoming. No pension information would be reported to IRS or recorded by SSA for an individual with continuous employment under a specific pension plan.