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Welfare Benefit Plan Filing

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I have a cafeteria plan covering several welfare benefit plans. Filing was never required since the number of participants in the component plans were less than 100 and a "Trust" was never established.

The plan sponsor is now closing the company so the plans will now be terminated. I read somewhere that even if fiing was never required, a final return must be filed for the cafeteria plan covering the welfare benefit plans.

Can anyone tell me if this is correct and if so, where can I find this information so I may show the client that we must file a final?

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