DFE GIA Filer

[Guest cease]

I have been asked to assist a client that participates in a GIA. Since the beginning of time, the client has been particpating in a GIA with a number of other unrelated employers. The GIA trusts established are for Group Health, Group Life, LTD and Dental. The participating employers remit premiums to the individual Trusts.

Until recently, the Form 5500 has been completed as a DFE and filed by the Trust. The client has just been told that the Trust will no longer file as a DFE and that each client must prepare their own 5500. Everything else will stay the same - participating employers will continue to remit premiums to the Trust.

A couple of questions...

1. Has anyone ever experienced a similar set of circumstances? If so, would you please direct me to some guidance?

2. If the employer is now required to file an individual 5500, do they file it as a multiple-employer plan?

3. Is the sponsor required to have an independent audit performed? Note: The participating employer that I am working with has greater than 250 participants in each Welfare plan.

I am sure that there is more information that is needed to make an accurate assessment - anything that anyone can offer in the way of direction would be appreciated.

Thanks.