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Depends on when the plan had over 100. If it's the first day of the first plan year, then yes. If it's not until the first day of a year after, then maybe not unless it's reached 120. But either way, the first sentence is irrelevant.

First, and this is semantics, but you're talking about a potential management function affiliated services group. No such thing as a management function controlled group. I say this only because when you are looking for formal guidance, which is somewhat sparse on this subject, it (the terminology) matters. Second, impossible to tell from the facts given. And this type of situation is very much driven by facts and circumstances. Have you already ruled out ANY type of attribution - not just family, but options, etc.? What is the precise relationship between the companies, and what functions are being performed, and by whom? You really should take this to an ERISA attorney.