Large Plan Filing - audit requirements

[Guest nps]

I am working on a plan that was required to have an audit completed for the past 2 years since they have had over 120 participants. They currently have less than 120 participants, and in the near future, hope to have less than 100 particpants.

Will they be able to file again as a small plan (using Schedule I), and not have to submit an audit with the filing? Or would they still have to file as a large plan (using Schedule H), but not have the audit requirement?

Thank you!

[WDIK]

It is my understanding that if the plan covered fewer than 100 participants as of the beginning of the plan year, that it can file as a small plan, using Schedule I and avoid the audit requirement (assuming of course that it meets the bonding requirement for non-qualified assets).