Final 5500 on merged plan

[dmwe]

A large plan money purchase pension plan was merged into a new 401k profit sharing plan. There will of course be an audit report for the profit sharing plan, but does there need to be a final audit report for the terminated and merged money purchase plan? The mppp was merged in March of 2010.

[J Simmons]

A large plan money purchase pension plan was merged into a new 401k profit sharing plan. There will of course be an audit report for the profit sharing plan, but does there need to be a final audit report for the terminated and merged money purchase plan? The mppp was merged in March of 2010.

When you say merged, do you mean that there was a plan (MPP) with a three-digit number (e.g., 001) and that there was also then created a new plan (k) with a different three-digit number (e.g., 002), and only after that new plan (k-002) was established there were additional documents prepared and signed on behalf of both plans, addressing the facts that (1) the assets of the MPP-001 would then be transferred to the trustee of the K-002, and (2) what responsibilities then that the trustee of the K-002 plan had?

Or was it merely a new k plan document was prepared that said it was restating and superseding the MPP plan documents, and that the three-digit number (e.g., 001) that applied before the new documentation would continue to be used?

The first situation is truly a plan 'merger' as prior to the asset/obligation transfer there were two separate plans, and after that transfer, only one plan continued to exist. In that case, you would have a 'final' Form 5500 and I would presume that an audit would be necessary (even perhaps more important to be able to make sure that the assets all track appropriately into the K-002 plan).

The second situation is sometimes called a "merger" colloquially but is not for purposes of the regulatory provisions. In that case, there would just be one 2010 Form 5500, not a separate "final" one for the MPP plan, but the single audit would cover both eras in 2010, that before the new K documentation and that part of 2010 after the new K documentation.

[dmwe]

The new 401k plan is plan #002. The sponsor has decided to try and get a quick audit on the closed MPPP. Maybe we'll get the requested extension to the Oct. 15th deadline. Otherwise the accountant will be scrambling.

Thanks