Self Funded Welfare Benefit Plan

[nancy]

Must a self funded plan with fewer than 100 participants file a Form 5500?

[Kirk Maldonado]

Do the instructions to the Form 5500 address this issue?

[Guest b2kates]

is the self funding held in a trust?

if so then the plan is "funded" and I believe that a filing would be required.

but it actually the funds are held in an employer account, then no filing needed.

[Kirk Maldonado]

Be sure that you are technically self-funded. There are some arrangements that often closely mimic self-funded arrangements that do not constitute "self-funding" for purposes of ERISA. There are even some court decisions that got this issue wrong.