Identification of Co-Sponsors on 5500

[ERISA1]

In the case of a "Multiple Employer" Plan, must the unrelated co-sponsors be identified on Form 5500 filings? I seem to recall that you needed to attach additional first pages of 5500 for each co-sponsors; however, I cannot find that requirement in the current 5500 instruction.

Am I correct in thinking the co-sponsor need not be identified? (Was there ever a requirement to do so?)

Thanks very much.

PS - This is a DC Plan, so there is no concern regarding Schedule SB.

[Andy the Actuary]

My proof of the pudding: I've been working for a multiple-employer plan for years. The participating employers are not noted on the 5500 and no forms have been returned nor does the auditor ever comment. Take a look at the MLB pension plan, you won't find the baseball clubs listed!

[MoJo]

...Take a look at the MLB pension plan, you won't find the baseball clubs listed!

The MLB plan is a "multi-employer" plan - not a "multiple employer" plan.

[MoJo]

In the case of a "Multiple Employer" Plan, must the unrelated co-sponsors be identified on Form 5500 filings?

Under DOL guidance issued earlier this year, if the entities aren't sufficiently related, what you have for DOL (and hence for Form 5500) purposes are SEPARATE PLANS requiring SEPARATE FORMS 5500 - albeit having been implemented using a single plan document.

What exactly do you mean by "unrelated"?

[ERISA1]

By "unrelated", I mean the employers are not members of a controlled or affiliated service group with each other. There is a very low level of common ownership. The motivating factor is to share investments without the need for a Common Trust.

I understand that discrimination testing is perfored on a disagregated (separate plan) basis. However, my question is focused on 5500 disclosure. It seems fairly clear to me that under these circumstances the Plan is a multiple employer plan for reporting purposes; must the identity of the co-sponsor be disclosed?

Thanks

[pmacduff]

There is an interesting write up by Derrin Watson...if you go to the Q&A columns on these boards and look at the last post from Derrin regarding MEPs.

I'd provide a link but I'm not sure how to do that!

[david rigby]

Derrin Watson's Q&A column: http://benefitslink.com/modperl/qa.cgi?db=qa_who_is_employer

The questions are in chronological order, most recent first. Start with No. 315.