welfare plan dfvc - missing 1st 2 yrs

[TPApril]

Company had over 100 employees from day 1 in 1996. we managed to obtain schedule A info back to 1998 for all carriers [whew], but only 1 carrier for 1996 and 1997 [darn]. That carrier shows under 100 employees. Company does not have records of employee counts in those 1st 2 yrs. Question:

Do we just file dfvc back to 1998?

Do we file back to 1996 with incomplete info for 1996-1997 showing < 100 employees?

[Bill Presson]

I would file from the first year and have the employer give their best estimates. We just went through a similar situation with an employer that had a tough time with their early records. Their first year was 1992.

I feel your pain.

[TPApril]

thank you for your reply. would you estimate both participant counts and premiums?

[Bill Presson]

thank you for your reply. would you estimate both participant counts and premiums?

I would have the employer estimate anything that was a required entry on the form otherwise it will kick out. Just have them document the reasoning behind the estimates.

[TPApril]

What are your thoughts on providing one historical SAR which lists the premiums for each year all on one page?

[Bill Presson]

What are your thoughts on providing one historical SAR which lists the premiums for each year all on one page?

Not a bad idea but we've done one for each year each time we've done this.

[Belgarath]

Just tossing out a thought FWIW. Why even bother with an SAR other than for, say, the last 3 years? It isn't filed with anyone, and there's no specific penalty involved. If the DOL or a participant asks for one, then of course you must produce one, but it seems unlikely they will.

[TPApril]

good point, especially considering the prospect of distributing it to the correct employees for each year.