QSLOB question

[Guest Bearlee]

Can a non-parent company in a controlled group arrangement file for a QSLOB election?

I am advising a plan sponsor that is part of a control group, which I think is in an industry outlined in Rev. Proc. 91-64 and I believe the plan sponsor is the only one in that industry in the control group -- so I believe the safe harbor is satisfied. My client, near the bottom of the food chain, has qualified plans and the only other qualified plans in the control group are sponsored by the parent.

Can my client file the 5310-A or does the parent company have to do it? Any input would be appreciated.