A plan was set up with a start date of 5/1/2015 for purposes of processing a plan transfer in from a multiple employer plan (MEP). However, per the document, contributions were stated to start deductions on 6/1/2015.
This plan had only 15 participants transfer money from their former plan under an MEP. The plan has > 150 people eligible on 6/1/15 (even though maybe 10 people actually contribute).
Would this plan qualify as a large plan and therefore have to have an independent audit for 2015, or do we say its a small plan for the initial year by using the 5/1/15 start date?
Thanks for any feedback.