TPApril Posted October 23, 2017 Share Posted October 23, 2017 Company files its 5500s appropriately for 5 different benefits on separate 5500's. They are consolidating and creating a wrap plan document effective beginning of current year, with brand new plan number. None of the current 'plans' have an existing ERISA plan document. In addition to the resolution adopting the new plan and wrap plan document, do other plans which will be filing 'Final' 5500's need plan termination resolutions, given that there has never been a plan document to begin with? Link to comment Share on other sites More sharing options...
C Health Posted October 24, 2017 Share Posted October 24, 2017 Another option to consider is to word the new wrap plan document in such a way that it includes language to terminate the previously existing plans. This information could also be included in the SPD which would indicate that the previous plans (complete with their plan name and number as stated on the 5500) have terminated and are superseded by this new wrap plan. This may be less confusing to participants than sending them a termination SPD. As for the resolution, this could be handled the same way; the enacting resolution could reference the termination of the earlier plans. Link to comment Share on other sites More sharing options...
SLuskin Posted October 24, 2017 Share Posted October 24, 2017 We have that come up all the time, and we just write the new wrap document and spd with the remaining plan number. If the other plans are filed as final, we do not prepare documents for those. However, we do include a statement in the new wrap document that says that this "new plan" is a consolidation of the following plan numbers ..... C Health 1 Link to comment Share on other sites More sharing options...
Flyboyjohn Posted October 24, 2017 Share Posted October 24, 2017 Wrapping the 5 plans together for 5500 filing purposes does not in any way "terminate" the plans, they just begin operating under the umbrella of a single plan document and reporting under a single 5500. Link to comment Share on other sites More sharing options...
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