5500 Audit

[Guest KWebb]

I'm reviewing a plan with the following:

- They have 0 participants at the end of the year

- They have $0 assets at the end of the year

- They had over 120 participants at the beginning of the year

- This is the final 5500 filing as the plan is terminated and all assets are paid out

- The company has been gone for about 5 years or so and the plan was still around because the trustee was working on getting a fair value for employees.

- No one has worked for the company for about 5 years

- The prior CPA said there is no money to even pay for an audit as no company exists to pay for it.

The client (well, someone...) received the typical DOL letter for the missing accountant's opinion. Is there any type of exemption from the audit requirement in a situation such as this? Who is responsible for the completion and the cost of the audit? Do we go back to whomever submitted the final Form 5500 report recently? Do we try to track down any fiduciary or trustee of the plan?

[PensionPro]

There is an exception to filing 5500 for the Qualified Termination Administrator (QTA) of an orphan plan. However, the plan sponsor remains liable for filing regular 5500 forms until final distribution. Who is signing the 5500 as plan sponsor?