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welfare plan dfvc - missing 1st 2 yrs

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Company had over 100 employees from day 1 in 1996. we managed to obtain schedule A info back to 1998 for all carriers [whew], but only 1 carrier for 1996 and 1997 [darn]. That carrier shows under 100 employees. Company does not have records of employee counts in those 1st 2 yrs. Question:

Do we just file dfvc back to 1998?

Do we file back to 1996 with incomplete info for 1996-1997 showing < 100 employees?

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thank you for your reply. would you estimate both participant counts and premiums?

I would have the employer estimate anything that was a required entry on the form otherwise it will kick out. Just have them document the reasoning behind the estimates.

William C. Presson, ERPA, QPA, QKA
C 205.994.4070
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