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Posted

Client just had a much-needed turnover in HR Department and the new director has discovered numerous Welfare Plan Form 5500 delinquencies, and numerous missing Form 5500 records. It's very hard to tell what plans have neen filed and for what years. We are looking at 2-4 plans.

QUESTION: Is it a good idea to contact the DOL to determine which plans have filed and for what years? Has anyone had experience with this? My inclination is to just assume that if we can't find it, it wasn't filed, and use the DFVCP $4,000 per plan cap instead of mucking things up with the IRS/DOL. I would want to include a cover letter explaining that we have refiled everything due to the defincient recordkeeping of prior HR personell.

Any thoughts? Good idea, bad idea, other idea?

Guest b2kates
Posted

Also, if the plans have more than 100 participants consider checking with the firms outside auditors.

Posted
freeERISA.com is a great resource, but it will have limited free access, generally only showing the prior two years. You can get other access for a fee, or a paid search. If you need actual copies of prior forms, probably only the DOL will be the appropriate source.

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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