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What is the Content of SBCs for HRAs

Based upon their content, language, etc., the SBC templates provided by the regulatory agencies do not appreciate the diversity in features of plans subject to the SBC requirement. The regulatory guidance (including the instructions for the template SBC) clearly acknowledges the possibility of plans not fitting the strict template structure. The guidance provides that where the plan’s terms “cannot reasonably be described in a manner consistent with the template and instructions, the plan or issuer must accurately describe the relevant plan terms while using its best efforts to do so in a manner that is still as consistent with the instructions and template format as reasonably possible.”

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