Who Technically Sponsors Orphan Plan -

[namealreadyinuse]

Corporate sponsor liquidates and individual trustees want to properly document orphan plan status. Do the individual trustees now sponsor the plan as individuals? We are used ot sole proprietor plans, but this really is not the same (and the trustees don't have businesses running as sole proprietors).

They essentially want to continue the plan as frozen (and an orhpan) for a while before terminating it eventually.

[WDIK]

I don't think an orphan plan has a sponsor.

I don't think that this is an abandoned plan as there are still fiduciaries acting forthe plan.

I don't think that the plan without a sponsor can continue as a frozen plan.

I don't think that the fiduciaries should delay in closing out the plan.

Some say that I just don't think in general.

[Ron Snyder]

Such an orphan plan is considered by IRS to be a wasting trust and must be liquidated within 12 months of becoming orphaned. It is not a frozen plan. If (a) some of the participants have gone to work for an employer who wishes to sponsor the plan, or (b) a company related to the original sponsor is willing, such employer may become a sponsor. Failure to liquidate in time by the trustees may result in their incurring personal liability for the plan's disqualification and pursuant negative tax implications.