On July 20, 2009, the Department of Labor (“DOL”) published Field Assistance Bulletin No. 2009-02 (“FAB 2009-02”), which provides guidance and transition relief for sponsors of 403(b) plans that will be required to file a more detailed Form 5500 annual report beginning with the 2009 plan year. While the guidance does not delay the annual reporting requirements, it does allow for reasonable good faith compliance and other transition relief that should assist plan sponsors in meeting their reporting obligations.
