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Posted

its a long story but the plan sponsor decided they didn;t want the plan in the first year and their lawyer determined that they can terminate the plan after making contributions to the nonhighly compensated employees. he also says to treat the plan as a nonqualified plan. i am not sure what is legal basis for this is but i don't really care. what i want to know is what we do regarding the form 5500 sf. i think we have to file a normal 5500 sf but does anyone know if any of the codes are different or if there is anything special that has to be done>? i see there is a code 1c for cash balance but also a code 3c for plans not intended to be qualified. do we use both 1c and 3c or just 3c.

Posted

It is my understanding, for what it is worth, that one uses as many of the codes as apply, not just one code chosen as the best descriptor.

If one is working with (for example) a frozen defined benefit plan using a volume submitter document, sponsored by a member of a controlled group, that had used a compensation based formula prior to the freeze and which is covered by the PBGC, you might show, as codes (please forgive me if I get any of these wrong) 1A, 1G, 1I, 3D and 3H.

Always check with your actuary first!

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