Spin-off from Multiple Employer Plan

[QNPG]

I have a plan which is a spin-off from a multiple employer plan. Considering a spin-off is a continuation of the MEP, should the new spin-off plan be numbered #001?

[12AX7]

I've done it several times by starting with #001, or the lowest unused plan number for that sponsor. I've seen others use the plan number and effective date of the MEP. I've not heard any bad news from the other side of the fence and none of my plans have been sidelined for the starting over method.

I do recall in the 2009 ERISA Outline Book there was commentary that appeared to support my method. I'll continue with the startover method until there is more specific guidance on this situation.