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Welfare benefit "wrap plan" 5500 filing


Guest jigpsu100
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Guest jigpsu100

We have a situation where we used to file separate welfare benefits plans for one employer. We have consoldated the plans into a "wrap plan." I know that it is permissible to file one 5500 for the wrap plan. How do I note on a 5500 that the plans used to be filed separately? May I just file the new plan? It doesn't seem correct to file final 5500s for each individual component, but I certianly don't want to red-flag anything with the Service. Does anyone have experience swtiching from filing individual plans to filing a wrap plan?

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My general experience is that the DOL prefers that you mark the last individual plan Form 5500s as the "final" filing for the plan and indicate that the plan had 0 participants at the end of the Plan Year. Assuming you established a brand new plan (brand new plan number, etc.) for the Wrap rather than just taking over the plan number of one of the existing plans, then I think you have technically terminated all the individual plans and established a new plan which is regarded as a separate legal entity. I would be interested in the experience of others in this area.

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401 Chaos,

We recently did this. Consolidated a bunch into one large plan. Filed all the originals as final and moved forward with new plan number in first year filing.

jigpsu100, am guessing this wrap plan covers 2004 filing. That means the original separate benefits terminated in 2003. You would go back and amend 2003 filings to be final.

If the wrap plan took over during the plan year you may be in trouble since the due date for filing 2004 filing for termed plans is 7 months after end of year. Example if the new wrap plan took over 7/01 then the termed plans are due 1/31/05 or with extention 04/15/05.

clear as mud?

JanetM CPA, MBA

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