Schedule SSA and Multiemployer Plan

[Guest TPAStacey]

Does anyone know of a reason why a plan would not file a schedule SSA for a multiemployer plan? I looked at the instructions to the Schedule SSA and it states..."In general, for a plan to which more than one employer contributes, a participant must be reported on Schedule SSA if: (1) the particiant incurs two successive 1-year breaks in service, and (2) the participant is (or may be) entitled to a deferred vested benefit under the plan."

We have taken over a new multiemployer plan that has over 3,000 participants but didn't have an SSA last year. Only employer contributions are made to the plan. I find it hard to believe out of that many partipants there's no one that doesn't need to be reported on Schedule SSA.

Any thoughts would be appreciated!