For plan years after 12/31/2007, PPA extended the Annual Funding Notice requirement under ERISA 101(f) to include not just multiemployer plans but also PBGC covered single employer plans. If I have this right, PPA also removed the Summary Annual Report requirement for all DB plans. Is it true that, starting with plan years beginning after 12/31/2007, there is no annual notice requirement for non-PBGC covered DB plans?

Under ERISA Section 101(f) as amended by the Pension Protection Act of 2006, the Annual Funding Notice requirement applies to any defined benefit plan which is covered by the PBGC effective for plan years beginning after 2007. However, the Summary Annual Report requirement was only eliminated for plans covered under ERISA Section 101(f) as amended [ERISA Section 104(b) (3)], so a defined benefit plan which is covered under Title I of ERISA but is not covered by the PBGC (and thus is not covered under ERISA Section 101(f)) still needs to provide a Summary Annual Report.

ERISA §104 - Filing and furnishing of information -

(b) Publication of summary plan description and annual report to participants and beneficiaries of plan.

Publication of the summary plan descriptions and annual reports shall be made to participants and beneficiaries of the particular plan as follows:

(3) Within 210 days after the close of the fiscal year of the plan, the administrator (other than an administrator of a defined benefit plan to which the requirements of section 101(f) applies) shall furnish to each participant, and to each beneficiary receiving benefits under the plan, a copy of the statements and schedules, for such fiscal year, described in subparagraphs (A) and (B) of section 103(b)(3) and such other material (including the percentage determined under section 103(d)(11)) as is necessary to fairly summarize the latest annual report.