I know it has been a while since any activity on this topic, but I have a related question that I cannot find an answer to. Scenario: New unfunded welfare plan with less than 100 participants at BOY - no need to file any Form 5500, right? But then we move to the next year and the BOY count is 102. Do they have to file as a large plan even though in the prior year they had less than 100 participants? Can you file a Form 5500-SF for the first year even though it is not required (just so you could file 5500-SF in the following year)?
