Leaderboard

I'd use the actual legal plan name as reflected on the document, and I'd also never worry about the IRS caring one way or the other unless the plan would also have much bigger fish to fry under an audit. You can update the name change on the 5500 after it's actually been effected.

And has no allocation conditions (no last day or minimum hours requirements). Runs concurrently. So a deferral of 6% of pay gets both matches in full.

And when you turn to reporting one or both changes, Form 5500 part II line 4 and the Instructions for it (page 18) state details about how to report a change in the plan’s name or a change in the sponsor’s name. The format recognizes that either of these names might have changed when the other has not. https://www.dol.gov/sites/dolgov/files/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2024-form-5500.pdf https://www.dol.gov/sites/dolgov/files/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2024-instructions.pdf

The IRS compliance questions apply to the 2024 Form 5500. While you are filing for a 2021 Plan Year, you are filing a 2024 Form 5500. You need to complete the questions.