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One of my clients reorganized in 2012 and as a result now have 4 unrelated employers in the plan. there is not enough common ownership to be considered a controlled group but I think they could be a ASG.

These are all companies that handle investments.

Company A is considered a Management company. They have all the administrative employees under them.

Company B handes the insurance investments,

Company C handles private investments

Company D handles real estate investments.

Could this possibly be an ASG?

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