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I think what Terry Power describes is what I meant. The merger-out might not be a termination such as to require immediate vesting for the transferred participants. But if the merger-out resulted in the single-employer plan’s assets and obligations becoming zero, that ends the single-employer plan (and the Form 5500 reporting should show the merger-out and end).

Good questions. The work that your client is asking you to perform is for the previously existing single employer plan for the 2022 short plan year. They (you) will need to file a "Final Form 5500" for that previous plan (with a final audit, if one is required) for 2022 and on that 5500 indicate that the plan was MERGED into the XYZ Pooled Employer Plan. It is almost certainly a plan MERGE, not a TERMINATION, btw. You may be able to reach out to the new TPA on the PEP for clarification. Happy to chat as well. Terry Power tpower@theplatinum401k.com 813.774.3366

We had this happen recently. Separate cash balance plan account and 401k plan account... but both under employer EIN. Worse, neither account reflected the plan name (cash balance or 401k). Applied for TIN for each plan. Sent client's authorization letters (one for each plan) to brokerage firm with full plan names and corresponding TIN's. Two new accounts were created, and assets moved from the old plan accounts to the respective new plan accounts. Seemed rather painless...

Any settlement check should be paid to the original owner (the plan) and it is simply different money, still owned by the plan. It is not a contribution. Getting the investment company to recognize that may be the hard part.