Multiple Employer Plan

[Guest Lex]

We have a mutiple employer plan (3 employers)

In 2000 our staff prepared the 5500 as follows (we have done this for several years)

1) One 5500 along with the appropraite schedules was sent under the main employers plan number (plan 333)

2) Another 5500 and only schedule T (no participant counts, no asset information) was sent as well for one of the other participating employers(001)

3) Another 5500 and only schedule T (no participant counts, no asset information) was sent as well for the other participating employer.(002)

The DOL sent the client a letter for 002 stating that the participant count and schedule H are missing.

I think we should have filed one 5500 with 3 schedule Ts.

Now the questions are:

1) Do you think my assessment is correct?

2) Should we respond to the letter by filing an amended return according to me approach- one 5500 plus all schedules (3 schedule Ts)?

3) If we do, how do we resolve the issue that there are plan nos. 001 and 002 out there? Will they not expect a filing for these as they have accepted this approach in the past?

[Archimage]

Your assessment is correct. You should have filed only one 5500 with a schedule T for each participating employer. You should file an amended return. Are the assets kept separately for each plan or do you have them comingled?

[Guest Lex]

The assets are all in one plan

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I meant are the assets kept separately for each employer just in case there is any confusion on what I meant. As long as your assets are held together in one trust account and file the amended 5500, I think that should be everything you need to do.