Plan name change - Welfare benefit plan

[Lori Friedman]

When a retirement plan (defers compensation; subject to a vesting schedule) changes its name, I.R.C. Sec. 6057 and its regulations provide some very clear rules about reporting the change. The plan administrator attaches an explanation to Form 5500 filed for the year of the change, and a failure to notify may result in a penalty.

What about a welfare benefit plan that's required to file Form 5500? I can't find any similar rule for reporting a welare benefit plan's name change.

Has anyone ever encountered this situation? I'm guessing that a welfare plan isn't required to report a name change, but that it's probably a really good idea to do so. Would you follow the same procedure as for a retirement plan? Example: the "Schlomo Brothers Health Plan" becomes the "Al & Greg Schlomo Health Plan"; would you attach a statement to Form 5500?

(NOTE. The plan sponsor's name hasn't changed, so Form 5500, Line 4 isn't used.)

[Ron Snyder]

We treat it the same. The plan's name is reported in item 1a under Part II, Basic Plan Information, for both retirement plans and welfare benefit plans.

Note: The Plan Sponsor's name is included in item 2a of form 5500.