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5500 required for group life, death benefits and/or group ad&d whe

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It is clear to me that the IRS is holding off on enforecment of filing requirements for certain "specified fringe benefit plans" under Section 6039D until more guidance is issued. However, it is unclear to me what 5500 requirements may still apply. If an employer is maintaining (1)a group term life insurance plan (self-insured); (2)weekly sickness and accident benefits plan(self-insured); and (3)$1200 death benefit payable (out of the employer's general assets)only to employees who reach a certain age before dying, and each of the foregoing plans has more than 100 participants, which, if any, are required to file a 5500?

Note: It is my understanding that the death benefit is a welfare plan under ERISA.

In determining the number of participants in the death benefit plan, would it be all employees since they are all potentially eligible for the benefit?

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