Wrap Document with Small Plan Component - Inclusion in 5500?

[holdco]

Good evening, everyone!

We have a client that sponsors an ERISA executive life insurance and executive disability plan. Each plan is fully insured, and has fewer than 100 participants. A few years ago, the client set up a wrap document that included all company benefits under one ERISA plan number (with separate SPDs for these two component small plans), several plans under which have more than 100 participants. There is little doubt that each executive plan standing alone would not need to file a Form 5500. However, what if it is part of the wrap? Should the details be included in the form of a Schedule A, or be named if self-funded and no Schedule A is available?

Can anyone point to any IRS or DOL authority on the subject? I can't seem to find anything conclusive.

Finally, is there any reason to think that a severance plan with more than 100 participants wouldn't need to file a Form 5500? I think ERISA covers these under Section 3(1)...

Thanks so much for the insight!

[Flyboyjohn]

I'll offer up a horseback opinion.

You file a 5500 for each "plan". Due to the wrap document you have a "plan" that provides multiple benefits, some of which if in a separate plan would not require 5500 filing, but because they've been wrapped into this single plan they should all be reported.

Agree that severance plans are reportable employee benefit plans.