participant count - union employees

[pmacduff]

I was sure this had been asked before but cannot find the thread or post:

Plan allows union employees to make 401(k) contributions only & they are excluded from all other portions of the Plan. The plan is a large plan and files as such with an audit report.

My question is: For purposes of the 5500 participant count do I include all union employees or just those who have chosen to defer and have a balance?

At this time it does not impact the filing type or audit requirement but could in the near future.

thanks in advance for any replies.

[Bird]

I think they're all participants, they just don't all have account balances.