When is someone a participant (again)

[BG5150]

Plan had a bunch of people who became eligible in 2007-2009 but were not informed of their ability to make 401(k) contributions. They all terminated in 2009 or '10.

In preparation of the 2010 analysis, in 2011, this was realized. Company made the requisite contributions and attendant matches and paid the people out (all were less than $100).

So, when are these people considered having account balances, and thus, participants again? When the deposit is made to the accounts (mid 2011)?

Do they get "retroactive" account balances back to 2007-2010?

This is extremely salient to my open participant count for 2011 form 5500.

[ETA Consulting LLC]

Your question is whether they should be included as participants in the beginning of the year (potentially making them a large plan in certain instances), or in the middle of the year (totally eliminating them from the count since they were fully distributed by year end). If I were doing it, they wouldn't be reflected in the count based on they way you explained it. So, they entered mid-year when they received contributions and left the plan when they were fully distributed.

Good Luck!