Determination Letter Cycles

[ERISA25]

Facts: Plan is Cycle B, so its cycle ends 1/31/2013; Plan will be terminated as of 1/15/2013.

Am I correct that the sponsor does not need to file a 5300 during its normal cycle, but may file a 5310 in connection with the termination instead? Any suggested approach?

[John Feldt ERPA CPC QPA]

Am I correct that the sponsor does not need to file a 5300 during its normal cycle?

I would not restate. Although the restatement requirement applies to plans that request a determination letter, I recall something about it not applying to plan terminations. I have not found the citation, so I could be in error.

Before submitting, be sure all interim amendments were timely executed. For example, a DB plan would need to have a Code Section 436 amendment adopted (if not already adopted).