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Indian tribes & 5500 reporting


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I've been searching thru the messages and it appears to me that Indian Tribes are considered "governmental" for ERISA purposes and therefore no 5500 needs to be done (message of 5/19/00). We have a 401(k) plan that we took over. They have an ERISA doc but the old TPA never filed a 5500 or did a val. They really only tracked the loans.

Is this reporting matter (5500) still a "grey" area or has anyone see anything recently that clarifies the reporting requirements?

Thanks for any input!

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