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Was it small enough to be able to force him/her out before the filing deadline? Anyway, a little common sense that you would have reported them earlier if they'd had that balance all along. Now they do, so the reporting obligation kicks in because after all, the whole point of the 8955 is to try to pair participants with their long lost funds so that they are reunited when applying for SSA benefits.

We are using it as a "hey let's not wait any longer to get that 5500 that's been sitting there for weeks to be e-filed, just in case the system crashes and no one is there to fix it".

Fire.gov is still accepting Form 8955-SSA submissions and sending confirmation receipt emails.

There has been prior discussion on this topic. Perhaps the Search feature will help you. There was also a Q&A in a prior Gray Book, and a verbal Q&A at a prior Enrolled Actuaries meeting. The IRS is sympathetic to such timing issues, so you can use 12/31/24 as the final date for Plan B for all purposes. Note that one second after midnight on 12/31/24, the Plan B assets are owned by Plan A, no matter where those assets are located; the "received" date is not relevant.

You would file the 2025 5500-EZ and check the retroactive adoption box. Of course an SB is still required to be provided to the plan sponsor, it just doesn't need to be attached or filed with the 5500-EZ.

To put some dates on the original question ... am I understanding it correctly, that you are talking about a plan adopted (say) 8/15/2025 with an initial effective plan year of 1/1/2024-12/31/2024? If that's the case, the first Form 5500 will be the 2025 form, due 7/31/2026 or 10/15/2026 on extension. You will check the box for a retroactively adopted plan on the 2025 form. You do not file a 2024 Form 5500 at all. However you will need to attach both the 2024 and 2025 Schedule SB to the 2025 filing.