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Past 5500's to include or exclude now sold off division

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Background:  Real Estate Investment Company owned 3 businesses, seemingly unrelated as they are in different states and simply different operations.  Benefit plans are operated independently at each location.  But there is common ownership. One of the 3 was sold off 2 years ago.

Company now realizes they needed to file welfare plan 5500's, so they are going back in time under DFVC, combining the two current locations with the intent to reduce the number of plan filings from the past.  Moving forward they will file as one wrap plan.

Question: To what extent should they worry about the now sold off location for those years?

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You can find your answer in the purchase agreement and the plan document where it defines who was the administrator for the plan.  Good luck.

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All benefits were managed by the local operation (there were no formal plan documents, just the service agreements with the carriers which current plan sponsor (and former owner) no longer has access to).

If I might add one piece of info to the original posting - all 3 operations had over 100 covered participants, so even stand alone they would have needed to file the 5500.

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If there was no plan document which defined the administrator then the employer was the administrator.    

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