pjr@frdayton.com

Will the IRS issue a private letter ruling with respect to the termination and final distribution of VEBA assets or is this a no ruling area. Thanks.

This vendor will do the analysis: https://nqtlanalysis.com/comparative-analysis-pricing/ They say the fee is $ 4000. If the TPA won't help here is an option.

Has anyone seen a sample or template for the new CAA Broker Compensation Disclosure form?

We have a small employer health plan that is maintained in conjunction with a trust. Therefore, it is funded and we file a Form 5500SF. We have assigned the filing Plan # 501. When the plan terminates the trust and switches over to a fully insured product we list Code 4R saying the plan will not file a Form 5500SF going forward. We believe this is better than indicating it is a final filing. In other words, the plan continues, but the funding method has changed; but the plan is not terminated. If we marked the filing as final, then we would have to use Plan # 502. Does anybody have any thoughts on this? Clearly we have to use Code 4R or mark it as final; otherwise the government will expect another filing. Again, we think the better approach is to use Code 4R rather than indicate it is a final filing when the employer simply continue the plan but changes the funding method. Thanks.