MP amended to PS

[Guest LVanSteeter]

A Money Purchase 401a amended and restated the plan document to become a 401k Profit Sharing on 3-1-2001.

Question: Do they get 2 5500s (Final year for MP, start up for PS) or 1? If they get one, do both 2c and 2e get input on the plan charateristics? Does the required contribution amount for the first two months get put on the Schedule R?

Are there ANY existing guidelines for this? This is becoming more and more prevalent with the new laws.

Thanks for the assistance!

[david rigby]

Is it one plan? If so, then one 5500.

[Guest LVanSteeter]

One plan administrator,

69 divisions that each file separately.

The plan wants to use the same plan name and three digit number.

[pjkoehler]

LVanSteeter: Since the effective date of the amendment apparently occurred during the 2001 plan year, the plan would have had MPP characteristics during the pre-effective date period and PSS characteristics thereafter. It would be logical to code the response to question 8a as you indicate. While there is nothing in the instructions that makes use of these two codes mutual exclusive, I guess it's not beyond doubt (but unlikely) that the IRS data match software could be designed to flag it and request a written explanation.

More importantly, I trust the plan sponsor was fully observant of the pre-EGTRRA version of ERISA section 204(h) notice requirements and the dash 6 regs under 1.411(d)? Failure to have satisfied these requirements is potentially disasterous.