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New Wrap Plan - termination amendments required for prior 'plans'?


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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?

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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that the previous plans (complete with their plan name and number as stated on the 5500) have terminated and are superseded by this new wrap plan.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. 

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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 .....

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